Privacy

EFFECTIVE DATE: October 1, 2015

RealBlocks Privacy Policy

On October 1, 2015, we published our Privacy Policy. Your use of RealBlocks means you agree to this document, so please take a few minutes to read and understand it. The RealBlocks mobile application and services, as well as the RealBlocks website located at www.RealBlocks.com (the “Site”) and any content therein (collectively, the “Services”) offer users a forum to interact with other RealBlocks users in the same area or regarding the same subject, in order to post and share comments, and to respond to comments posted by others. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about users of our Services, which are available via mobile applications (the “App”) and/or the Site.

What Information We Collect

The categories of information we collect can include:
  • Information you provide to us directly. We may collect personal information from potential investors and issuers, such as your name, telephone number, email address, information about your company, and investment or fundraising information, as applicable, when you when you register for our Website, sign up for our email updates, request information, or otherwise communicate with us. We may also collect any communications between you and RealBlocks and any other information you provide to us.
  • Information we receive from third parties. From time to time, we may receive information about you from third parties, such as third parties we use to conduct identity verification and to verify accredited investor status. We may also collect information about you that is publicly available.
  • We use this information to operate, maintain, and provide to you the features and functionality of the Website, as well as to communicate directly with you, such as to send you email messages, including our Newsletter and other email updates, or call you in response to your request. We may also send you Website-related emails or messages (e.g., account verification, change or updates to features of the Website, technical and security notices). For more information about your communication preferences, see “Accessing and Modifying Information and Communication Preferences” below.
  • Information We Collect Automatically. We may automatically collect information about your use of the Services such as: access time, device ID, application ID or other unique identifier; domain name, IP address, screen views; geo-location data (with your permission); language information; device name and model; operating system information; your activities within the Services; and the length of time that you are logged in. We may combine this information with other information that we have collected about you.
  • Social Media Sites. You can like us on Facebook, follow us on Twitter, and promote us on other social media sites. We collect information about who has liked us or followed us. However, we don’t associate your social media account with your RealBlocks account. You may also share Thoughts through Facebook, Twitter, Instagram, and other social media accounts.
  • Do Not Track. We support the Do Not Track browser setting. Do Not Track (or DNT) is a preference you can set in your browser to let the websites you visit know that you do not want them collecting certain information about you.

How We Use Information We Collect

In general, we use the information we collect from and about you to provide and operate the Services, respond to your requests, and to provide customer service and technical support. We may also use information:
  • To place you in your local RealBlocks group so that you can post and review content based on your current location.
  • To place you in your home RealBlocks group so that you can post and review content in your community even when you are away.
  • To tailor the information that we may send or display to you, offer location customization, send you push notifications and alerts, and to otherwise personalize your experiences while using our Services.
  • To send you notices.
  • To display advertising, including advertising that is targeted to you based on your location, as well as your RealBlocks activities.
  • Verify your identity and prevent spam or other unauthorized or illegal activity.
  • To better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Services and respond to user desires and preferences, and for other research and analytical purposes.

Where Information is Processed

RealBlocks is based in the United States. No matter where you are located, you consent to the processing and transferring of your information in and to the U.S. and other countries, you also consent to your information being present on servers in the U.S. The laws of the U.S. and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live. And, your information may be made available to government or law enforcement requests.

How We Share Information

You cannot control who views your content; any content you post is publicly available. So, if you don’t want to share something publicly, don’t post it. RealBlocks is a social network, and the content you post may be shared with and viewable by others. We do not identify you by name or contact information to other RealBlocks users. However, we cannot prevent others from determining your identity from the content you post or how you share content through third party sites.
The information we collect may be shared as follows:
  • RealBlocks Users. Any information that you post, including comments, replies and other information is publicly available. We cannot control how your information is used by others. Your posts are available to all other users. Users can also freely share any RealBlocks content, no matter who posted it, through other third party sites like Facebook, Twitter and Instagram. And, your posts may be publicly distributed outside of RealBlocks by us or third parties.
  • Service Providers. We may disclose the information we collect to third party vendors, service providers, contractors or agents who perform functions on our behalf.
  • Business Transfers. We may transfer the information we have collected to another company in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
  • Third Parties and Partners. We may share the information with our third party partners, including advertisers and researchers. For example, if you post content that mentions one of our advertisers, we may share that content with them. Or, we may work with a researcher to analyze the content on a particular feed.
  • In Response to Legal Process. We also may disclose the information in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process. For example, we may share your IP address or other identifier, your location information, or any other information we have collected about you and your device.
  • To Protect Us and Others. We also may disclose information if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which RealBlocks is involved.
  • Aggregate and De-Identified Information. We may also share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

Accessing and Modifying Information and Communication Preferences

If you have provided us any personal information, you may access, remove, review, and/or make changes to the same by contacting us at [email protected] In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any RealBlocks marketing email. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

Invite Contacts

You can choose to “Share RealBlocks” by inviting contacts via email, text or other means. You choose what contacts to invite and when to invite them. If you invite a contact, we assume implied consent and will generate a message with the RealBlocks download URL included, which you can choose to send via your mobile device.

Your Content

You can delete content you have posted (including replies). Content you delete will be hidden from other users. However, RealBlocks may maintain a copy of such content in our records.

Push Notifications/Alerts

We may send push notifications or alerts to your device. You can deactivate these messages at any time by changing the notification settings on your device or by changing your RealBlocks settings.

Third Party Analytics

We may use automated devices and applications, included those offered by third parties to evaluate usage of our Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. The information collected may include unique device identifiers, device manufacturer and operating system, IP address, browser type, session start/stop time, and user activity. From within the App, you may opt out of the collection of this information by third party analytics companies for the App (but not for the Site) by adjusting privacy settings. The opt-out is not available on the Site. Please note that if you choose to opt out of any data collection, that opt-out will not result in the deletion of data that has already been collected from the App. We also use third-party remarketing services (including Facebook and Twitter) to advertise on third party websites to previous visitors to our Site. It could mean that we advertise to previous visitors who have completed a task on our Site, for example using the Request a Demo page to request a demo of our products and services. These third-party remarketing service providers use cookies to serve ads based on a past visit to the Site. Any data collected by such third party remarketing service providers will be used in accordance with this Privacy Policy and the privacy policy of such third party remarketing services provider. For more information on such third party remarketing service providers, including how to opt out from certain data collection, please visit the following links: For Google Analytics, please visit:
https://support.google.com/analytics/answer/6004245 https://support.google.com/analytics/answer/2700409
For Facebook, please visit:
https://www.facebook.com/full_data_use_policy
For Twitter, please visit:
https://ads.twitter.com/terms/us#twitter-conversion-tracking-terms https://ads.twitter.com/terms/us#tailored-audiences-terms https://support.twitter.com/articles/20170405
For LinkedIn, please visit:
https://www.linkedin.com/legal/privacy-policy

Third Party Ads

We may share Other Information about you with third parties for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, and retargeting), analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable us, and these third-parties, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. You may opt-out of the tailoring of advertising based on information we collect. To learn more about the use of this information, or to choose not to have this information used by our providers or third party advertising partners by opting out, please visit the Network Advertising Initiative by clicking http://www.networkadvertising.org/managing/opt_out.asp.

Third-Party Links

Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites.

Minors

You must be at least 18 to use our Services. If you are not at least 18, please do not use our Services or provide any information to us. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at https://www.realblocks.com.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site, at https://www.realblocks.com. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site, or providing notice in our mobile app.