privacy policy

Overview

• By accessing and using the Site, you consent to our practices detailed in this Privacy Policy. To prospectively change your consent, you should stop using the Site.
• Third parties may collect information about you on the Site through the use of Tracking Technologies (defined below), which may include the collection of information about your online activities over time and across third-party web sites or online services. Their privacy policies, not ours, govern their practices.
• We ask you for, and use technology to detect, information about you. Some of this information is shared with others.
• Currently, we do not monitor or take any action with respect to third-party signals for the expression of choice regarding collection of information about an individual over time and across third-party web sites or online services (e.g., browser do not track signals), but you may have certain other options regarding tracking or targeting.
• Click here for a table of contents of topics covered. You may click on any topic to go to the details.

Introduction

Welcome! You have arrived at www.newryesecurities.com that is owned and/or operated by [New Rye Securities, LLC] (“NRS” or “we,” “our” or “us”). This “Privacy Policy” governs your use of any web site or other online service location (collectively, the “Site”) that posts a link to this Privacy Policy (including, without limitation, both mobile and online versions of any such site). This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Site (unless otherwise stated below).

To the extent we provide you notice on our Site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the Site’s Terms of Use, which governs your use of the Site. By using our Site, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below.

New Rye Securities Linkable Table of Contents

1. What Information Does the Site Collect?
   1. Information You Provide to Us

      You may give us Personal Information and Demographic Information, such as when you utilize a contact us feature through the Site. More

   2. Information We Collect and May Store as You Access and Use the Site

      Certain information may be collected from you automatically when you access and use the Site. For example, we and third parties may use Tracking Technologies to collect Usage
      Information based on your Device Identifier for a variety of purposes, which may include activities across time and third-party locations. More

   3. Information Third Parties Provide About You

      We may obtain information about you from third parties. More

2. How Do We Use the Information Collected?

   We use your Personal Information, Demographic Information and Usage Information for a variety of purposes detailed in this section. More

3. How and When Do We Share Information with Third Parties?

   We may provide your information to third parties under various circumstances detailed in this section. These may include:

   1. When You Request Information From or Provide Information to Third Parties

      If you request information from third parties, request that we send information to third parties or interact with third-party sites, we may share your information with such parties and/or they may collect your information directly. More

   2. Third Parties Providing Services on our Behalf

      Our vendors may collect your information or we may share it with them. More

   3. Administrative and Legal Reasons

      There are a variety of administrative and legal reasons for which may share your information. More

   4. Affiliates and Business Transfer

      We may share your information with our affiliates or in the event of a sale, merger or similar transaction. More

4. Do Third-Party Content and Links to Third-Party Sites Appear on the Site?

   We may allow you to access third-party content on the Site, or to link to third-party applications and locations from the Site, but we are not responsible for your interaction with third-party content, apps and locations. More

5. How Do I Change My Information and Communications Preferences?

   You may change certain information and communications preferences as more fully detailed in this section. More

6. What About Transfer of Information to the United States?

   Data may be transferred to the United States if you access the Site from outside of the United States. More

7. What Should Parents Know About Children?

   We do not intend to collect Personal Information from children. If you think we have, let us know. More

8. What About Confidentiality and Security?

   No data security is absolute, but we take reasonable steps to secure data appropriately. More

9. What About Changes to the Privacy Policy?

   We may change this Privacy Policy upon posting of a revised Privacy Policy. However, we will continue to treat your Personal Information under the terms of the privacy policy in effect when it was collected unless you otherwise consent. More

The Full Detailed New Rye Securities Privacy Policy

1. What Information Does the Site Collect?

   1. Information You Provide to Us

      On the Site, we may ask you to provide us with certain categories of information such as: (i) personally identifiable information, which is information that identifies you personally, such as your first and last name, home address and email address (“Personal Information”); and (ii) demographic information, such as information like your type of business, income, net worth, revenues, education level and occupation (“Demographic Information”). We may collect this information through various forms and in various places on the Site, including through “contact us” forms, or when you otherwise interact with the Site. If we combine Demographic Information with the Personal Information we collect directly from you on the Site, we will treat the combined data as Personal Information under this Privacy Policy.

   2. Information We Collect and May Store as You Access and Use the Site

      In addition to any Personal Information or Demographic Information that you choose to submit via our Site, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Site (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may be non-identifying or may be associated with you. To the extent we associate Usage Information with your Personal Information, we will treat it as Personal Information.

      This Usage Information may include:

      • your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;
      • your Device functionality (including browser, operating system, hardware, mobile network information);
      • the URL that referred you to our Site;
      • the areas within our Site that you visit and your activities there, including remembering you and your preferences;
      • your Device location;
      • your Device characteristics; and
      • certain other Device data, including the time of day, among other information.

      We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

      Cookies. A cookie is a data file placed on a Device when it is used to visit the Site. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies go to Adobe’s web site www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our Site may not function properly, and that when you revisit our Site your ability to limit cookies is subject to your browser settings and limitations.

      Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Site’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many emails that were sent were actually opened or to count how many particular articles or links were actually viewed.

      Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

      Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

      ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.

      We may use Tracking Technologies for a variety of purposes, including:

      Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Site, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Site functionality.

      Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of our analytic practices or otherwise to improve the investment opportunities, products or services offered through the Site.

      Functionality Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Site, including keeping track of our specified preferences, including in terms of the presentation of content on our Site.

      Targeting Related. We may use Tracking Technologies to deliver investment opportunities and similar content relevant to your interests on our Site and third-party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that we make available to you.

      There may be other Tracking Technologies now and later devised and used by us in connection with the Site. Further, third parties may use Tracking Technologies in connection with our Site, which may include the collection of information about your online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Site and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. Also, various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

   3. Information Third Parties Provide About You

      We may receive information about you from your contacts and others that use the Site. Additionally, we may, from time to time, supplement the information we collect directly from you on our Site with outside records from third parties, for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you investment opportunities. For example, users of the web site www.icrowd.com (the “iCrowd Site”) may authorize the sharing of their information with NRS through the functionality made available on the iCrowd Site. Once a user on clicks on an investment opportunity on the iCrowd Site and consents to the sharing of their information with a broker-dealer, his or her investor registration information may be shared with us with respect to such user’s specific interest in that investment opportunity we made available on the iCrowd Site. We may also collect information about you from consumer reporting agencies. To the extent we combine information we receive from those sources with your Personal Information we collect on the Site, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.

2. How Do We Use the Information Collected?

   We may use your Personal Information, Demographic Information or Usage Information that is subject to this Privacy Policy: (i) to provide you with information or services or process transactions that you have requested or agreed to receive including to send you investment opportunities on behalf of us or third parties; (ii) to enable you to participate in a variety of the Site’s features; (iii) to verify whether you are an accredited investor; (iv) to improve the Site or our services, to customize your experience on the Site, or to serve you specific investment opportunities; (v) to contact you with regard to your use of the Site and, in our discretion, changes to the Site and/or Site policies; (vi) for internal business purposes; and (vii) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

3. How and When Do We Share Information with Third Parties?

   We may share non-Personal Information, such as aggregated user statistics, with third parties. We may share your Device Identifiers with third parties along with data related to you and your activities. We do not share your Personal Information with third parties for those third parties’ marketing purposes unless you consent to such sharing at the time you provide your Personal Information. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. We may share your information as follows:

   1. When You Request Information From or Provide Information to Third Parties. You may be presented with an option on our Site to receive certain information and/or investment opportunities directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third party privacy policies and practices of such third parties.
   2. Third Parties Providing Services on our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Site, such as hosting the Site, designing and/or operating the Site’s features, for verification of investor status, tracking the Site’s activities and analytics, and enabling us to send you investment opportunities or perform other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. If you request that we share information with third parties, such authorization also applies to our third-party content providers. Third party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including your Personal Information. We are not responsible for those third-party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here [LINK TO CHART AT END OF POLICY]. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
   3. Administrative and Legal Reasons. We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information), including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Site’s Terms of Use or other policies applicable to the Site, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Site or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.
   4. Affiliates and Business Transfer. We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

4. Do Third-Party Content and Links to Third-Party Sites Appear on the Site?

   The Site may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you. In addition, when you are on the Site you may be directed to other sites that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their site and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Site onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave our Site and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

5. How Do I Change My Information and Communications Preferences?

   You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided to us. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or in some cases by logging into your Site account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Site, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it or would like to change your information or communication preferences, you should contact us in the following ways: Postal Mail: [New Rye Securities, LLC, 16 Brook Lane, Rye Brook, NY 10573 (Attn: Legal)]; by email: [legal@newryesecurities.com].

6. What About Transfer of Information to the United States?

   Our Site is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

7. What Should Parents Know About Children?

   The Site is a general audience web site and we do not knowingly collect any personal information from children younger than the age of 13 as required by U.S. law. We will delete any personal information collected that we later determine to be from a user younger than the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us, please contact us by email at [legal@newryesecurities.com].

8. What About Confidentiality and Security?

   We restrict access to your Personal Information to employees who need to know that information to provide products or services to you. We incorporate commercially reasonable, physical, electronic and procedural safeguards that comply with federal standards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.

9. What About Changes to the Privacy Policy?

   We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Site indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.