The Carlton Group, the service provider that powers this website, values your privacy. The following policies apply to the collection of data by us. If you have questions or concerns regarding this statement, please contact us at firstname.lastname@example.org.
This policy discloses what information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any personal or personally identifiable information that we may request will be used. We also detail below our security policy, which describes how your personal information is protected.
Information We Collect From You and About You
We collect personal and financial information from you while you navigate and use the website located at http://www.carltoncrowdfund.com (the “Site”). Most of the information collected is required for legal or security purposes, although some is optional. Additional information may be gathered during your subsequent use of the Site, whenever you choose to provide it; but in order to make investments through the Site, certain information must be provided.
In general we collect the following types of information from you:
- Personal data required to verify your identity
- Personal and financial data necessary to assess your eligibility to invest on the Site
- Information about your visits to and use of the Site to help us maintain the appropriate features, functionality and user experience
- Certain personal information must be supplied during the investor registration process, as indicated below, in order to (a) enable you to log in to the Site, (b) establish your ability to view offering materials and to make investments through the Site (for U.S. residents, such ability is restricted to “accredited investors” with a certain level of annual income or net worth), (c) verify that you are at least 18 years of age, (d) guard against potential fraud, (e) contact you if there is a problem with your account, and (f) maintain regular communications with you as may be necessary to inform you of upcoming investment opportunities and other Site updates. This basic personal information may include your name, email address, home address, phone number, date of birth, social security number and/or tax identification number, employer, and job title.
When you subscribe to make an investment in one of the opportunities listed on the site, you will again be asked for some of the same personal data as well as some additional data, such as your bank routing number and bank account number. This data is needed in order to enable us to utilize your bank account to originate funds transfers and later to make any investment disbursements to you.
In addition, we gather names and email addresses of users who contact us through the Site with questions about our company or our investments. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people.
Finally, we collect information about your computer and your visits to the Site, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies and other marketing activities. We use non-identifying and aggregated information to help optimize the Site based on the needs of our users.
Notifications and Communications From Our Site
We will send you email notifications from time to time. Such notifications are required elements of your transactions on our platform, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status such as when you are confirmed as an investor, or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that another person cannot make a change to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or Site policies. Generally, you may not opt out of such service-related emails.
When you register as an investor, you will receive emails that confirm specific actions you requested; these will include emails to which you must respond to complete your registration, and notifications confirming your registration. Thereafter, you will receive emails when a new investment opportunity is offered, as well as updates concerning the progress of the funding of such investment opportunity or other relevant information. If you make an investment through the Site, we will also send you confirmations of the investment and occasional updates as to the status of that investment and the timing of distributions relating to that investment. We may also send you responses to emails you send us, if appropriate. From time to time, we may also send user surveys, requests for user feedback regarding user experience and Site operations or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.
How and When Your Information Is Shared With Other Parties
We do not sell or rent personal information about our users for marketing purposes. We do, however, work with a number of trusted partners who perform vital functions as part of our operations.
We also work with (among others) providers of hosting services for the Site, electronic signature providers, and electronic payment service providers. We may engage third parties to help us to carry out certain other internal functions such as account processing, client services or other data collection relevant to our business; examples of such companies might include companies that perform data processing, reporting, tax documentation, custody or escrow services. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or to perform other specific services, like collections. Our providers are legally required to keep your information private and secure.
Your investment profile information may, in a generic way, be made publicly available on the Site or in summaries of aggregate investment data.
If you use our blog on the Site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of this forum, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in this forum.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of detecting and/or limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or our service, or to protect the rights, property or personal safety of Carlton Group, Inc., its users, issuers, or others.
Where You Can View and Correct Your Information
Web-Related Information Collection
We [(or our service providers, such as Google Analytics, or others)]  may also collect web surfing data related to your use of the Site. This may include, for example, information regarding which of our web pages you access, the frequency of such access, and your product and service preferences. This data collection may be accomplished by using cookies, web beacons, page tags or similar tools that are set when you visit the Website. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you visit the Site. Web surfing data and similar information may be used for administrative purposes, to assess the usage, value and performance of our online products and services, and to improve your experience with the Site. As with cookies, the web surfing information collected is aggregated, anonymous “click stream” and transactional data, and is not associated with any users as individuals.
Links to Other Sites
The Site may be accessed by users located outside the United States. If you choose to use the Site from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States, and that by providing your personal information on or through the Site that you consent to such transfer.
We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include firewalls and encryption, internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems. We limit access to the personal information we have about you to those employees who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. The Site is built upon a secure infrastructure with multiple layers of protection and we use industry standard encryption technologies to safeguard your information.
We retain non-personally identifiable information for up to two years. Any search strings we collect are converted to non-personally identifiable information, and the raw data is stored on our server logs for up to 90 days. Aggregate reports generated from such information may be kept longer.
Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Site. Generally, identification and authentication take place through the use of your user name and a password and/or while logging in with one of our technical support staff.
If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Site in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
You can take several precautions to protect the security of your computer and personal information. For instance, you can use a well-chosen password, and restrict access to your email account. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on the Site, be sure that you log out and close the browser window.
You should also be aware of fraudulent attempts to gain access to your account information known as “phishing,” whereby scammers try to bring unsuspecting people to a website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on a fake website, scammers will ask for login information to gain access to people’s accounts and withdraw their money.
We will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go the website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain. In the case of Carlton Group, Inc., you should always ensure the URL begins with http://www.carltoncrowdfund.com.