Privacy Policy

Syndicately LLC (the “Company,” “we,” “us,” or “our”) is committed to protecting your privacy. Your privacy is important to us. It is our policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you on our website, https://www.syndicately.com/ (the “Website”). This Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.

In the event our Website contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to your activities after you leave our Website.

Information We Collect

We collect several types of information from and about users of our Website (“personal information”), including information:

• By which you may be personally identified, such as name, user name, home address, work address, gender, e-mail address, marital status, telephone number, social security number, tax ID number, employer ID number, government ID number, passport information, picture, billing address, professional history, copies of identification forms, money transfer instructions, funds transfer accounts, investment documents, credit reports and history, and other identifiers by which you may be contacted online or offline;
• Financial information such as bank account information, financial objectives, transaction history, salary, investment documents, financial statements, assets, investments, estate planning information, and ownership and control affiliations and relationships; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• From third parties, for example, our business partners.
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.
• Information contained in documents that you upload to us.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

From Third Parties

We obtain information from third parties that we work with or engage in connection with our services, including partners such as banks and payment processors, background verification services, credit reporting agencies, government databases, identity verification services, and third parties that may assist with the assessment of your eligibility or suitability to participate in certain opportunities or services.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website or interact with content sent to you by users of our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information that tracks when and how you interact with content sent by us and by other users of the Website;
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See Your Rights and Controlling Your Personal Information for information on how you can opt out of behavioral tracking on the Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Provide services to you through the platform offered through the Website.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information

We use and disclose information that we collect about you or that you provide to us, including any personal information:

• To present, develop, improve, maintain and deliver our Website and its contents and services to you.
• To provide you with the fund formation, special purpose vehicle, fund management and other services provided through the Website.
• To allow fund sponsors, investment leads and other investors to discover and communicate with potentially qualified investors.
• To allow users of the Website to communicate with each other.
• To allow users of the Website to track how, when and by whom content sent from the Website is interacted with;
• To determine your eligibility or suitability for various services and opportunities.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To comply with regulations requiring us to identify our users and customers and related parties to regulatory, oversight, government, industry or compliance bodies.
• To make and file tax and other compliance reports.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data.

Disclosure of Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide:

• To our subsidiaries and affiliates.
• To other users of the Website where we have obtained your information at their request or initiation, through their use of the Website or where they have contacted you and asked you to provide such information.
• To users of the Website that send content from the Website to you.
• To fund sponsors and investment leads on the Website.
• To other users of the Website that you interact with on the Website, such as fund sponsors, investment leads, and other users and investors, and employees, agents, directors, representatives, and affiliates of such persons, including administrators, attorneys, advisors, accountants, and other third-party service providers.
• To third parties that you invite to access the Website, such as investment advisors, accountants, attorneys, administrators, and tax advisors.
• To auditors, accountants, certification providers, and other financial, accounting, security, and process auditing, attestation and certification groups.
• To contractors, service providers, and other third parties, including data centers, website application developers, hosting providers, maintenance services providers, backup services, storage application and facility providers, infrastructure providers, investment advisors, investment management services providers, software licensors, database providers, data security providers, privacy services providers, financial institutions, banking partners, credit reporting agencies, verification services, background and screening services, compliance review services, legal and accounting service providers, insurers and brokers, payment processors, and other third parties we use to support our business and the services we provide to you and our other customers.
• To international, state, federal, and local governments, quasi-governmental bodies, self-regulatory agencies, industry oversight, regulatory and governance bodies, tax and revenue agencies, securities regulatory agencies, professional groups and associations, corporate oversight regulators, securities regulators, banking regulators and other regulators.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Syndicately’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Syndicately about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use (See our Terms of Service) and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Syndicately, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction and increased privacy security.

Your Rights and Controlling Your Personal Information

• Your choice: We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or by sending us an email stating your request to . If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
• Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such a person’s consent to provide the personal information to us.
• Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
• Access: You can review and change your personal information by logging into the Website and visiting your account profile page. You may also send us an email at to request access to, correct, or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
• Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
• Removal: We are not responsible for revising or removing your personal data obtained by any third party who has previously been provided your information by us in accordance with this policy or any third party to whom you have provided such information (whether by sharing your login and password, or otherwise).
• Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
• Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
• Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
• Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. We use computer safeguards such as firewalls and data encryption, enforce physical access controls to our buildings and files, and authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.

You are responsible for selecting any password and its overall security strength, ensuring the security of your information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

Retention of Your Personal Information

We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including the purposes of satisfying any legal, accounting, or reporting obligations or resolving disputes.

Children’s Privacy

We do not aim any of our products or services directly at children under the age of 18, and we do not knowingly collect personal information about children under 18.

Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

Limits of Our Policy

Our Website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.

Your Rights as a Data Subject (GDPR)

The information provided in this section applies only to individuals in the European Economic Area, United Kingdom and Switzerland (collectively, “Europe”) and explains our practices regarding personal information that we collect from you or which we have obtained about you from a third party and the legal basis for processing for your personal information. It also sets out your rights in respect of our processing of your personal information.

EU Personal Information. References to “EU Personal Information” in this EU Data Rights section are equivalent to “personal data” governed by the General Data Protection Regulation (GDPR).

Controller or Processor. We may be either the controller or processor of your EU Personal Information covered by this Privacy Policy, as stated under the heading “Information We Get From Others”.

Privacy contact. Privacy and data-protection questions can be sent to .

Legal basis for processing. The legal bases of our processing of your EU Personal Information will depend on the type of EU Personal Information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We use your EU Personal Information only as permitted by law.

Your rights: You have the following rights in relation to the EU Personal Information we hold about you:

• Right of access: You can ask us if we are processing your EU Personal Information and to provide you with a copy of it (along with certain details). If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If the EU Personal Information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified.
• Right to erasure: You can ask us to delete or remove your EU Personal Information in some circumstances such as where we no longer need it or if you withdraw your consent to our processing of your EU Personal Information (where applicable).
• Right to restrict processing: You can ask us to “block” or suppress the processing of your EU Personal Information in certain circumstances, such as where you contest the accuracy of that EU Personal Information.
• Right to data portability: You have the right, in certain circumstances, to obtain EU Personal Information you have provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
• Right to object: You can ask us to stop processing your EU Personal Information, and we will do so, if we are:
  • relying on our own or someone else’s legitimate interests to process your EU Personal Information, unless we can demonstrate compelling legal grounds for the processing; or
  • processing your EU Personal Information for direct marketing purposes.
• Right to withdraw consent: If we rely on your consent (or explicit consent) as our legal basis for processing your EU Personal Information, you have the right to withdraw that consent at any time.
• Right to lodge a complaint with the supervisory authority: If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to the relevant Supervisory Authority.

You may submit these requests by email to . We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. We will tell you why if we decline your request, subject to legal restrictions.

Cross-border data transfer. If we transfer your EU Personal Information out of Europe to a country not deemed to provide an adequate level of personal information protection for purposes of applicable data protection laws such that additional safeguards are required, the transfer will be performed:

• pursuant to the recipient’s compliance with Standard Contractual Clauses;
• pursuant to the consent of the individual to whom the EU Personal Information pertains; or
• as otherwise permitted by applicable laws.

You may contact us if you want further information on the specific mechanism used by us when transferring your EU Personal Information out of Europe. You can find out more about the GDPR and your rights by accessing the European Commission’s website.

If required by law, we will get your permission or allow you to opt in or opt out, as applicable, of any new uses of your personal information.

California Privacy Rights

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“CA Personal Information”). CA Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of CA Personal Information from consumers within the last twelve (12) months:

We obtain, use, disclose and share the categories of CA Personal Information listed above as described elsewhere in this policy.

Sharing CA Personal Information

In the preceding twelve (12) months, Company has disclosed CA Personal Information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell CA Personal Information. In the preceding twelve (12) months, Company has not sold CA Personal Information to the categories of third parties indicated in the chart below. For more on your CA Personal Information sale rights, see CA Personal Information Sales Opt-Out and Opt-In Rights.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their CA Personal Information. This section describes CCPA rights of California residents and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your CA Personal Information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:

• The categories of CA Personal Information we collected about you.
• The categories of sources for the CA Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that CA Personal Information.
• The categories of third parties with whom we share that CA Personal Information.
• If we sold or disclosed your CA Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the CA Personal Information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the CA Personal Information categories that each category of recipient obtained.
• The specific pieces of CA Personal Information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your CA Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the CA Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Correct

You may request correction of inaccurate CA Personal Information that we maintain about you, subject to applicable law.

Right to Limit Use and Disclosure of Sensitive Personal Information

Where this right applies, you may ask us to limit our use and disclosure of sensitive personal information to purposes allowed by law. Send requests to .

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request:

• Emailing us at

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your CA Personal Information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected CA Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with CA Personal Information if we cannot verify your identity or authority to make the request and confirm the CA Personal Information relates to you.

You do not need to create an account with us to submit a request to know or delete. We will only use CA Personal Information provided in the request to verify the requestor’s identity or authority to make it. We do not sell the CA Personal Information of consumers. You do not need to take any action to Opt Out of sales of CA Personal Information.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact .

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your CA Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

CA Personal Information Sales Opt-Out and Opt-In Rights

We do not sell the CA Personal Information of consumers. You do not need to take any action to Opt Out of sales of CA Personal Information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your CA Personal Information value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to .

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: