Effective: 06 April 2015
Unless stated otherwise, this Policy only addresses the use and disclosure of information we collect from you online through our Site. We may collect and transfer information to a service provider or partner, or other third party without your consent, where allowed by applicable law.
Through your continued use of our Site, or by providing your Personal Information to us, you consent to the practices described in this Policy.
1. Additional Agreements
2. What Information do we collect and how do we use it?
For the purposes of this Policy, “Personal Information” means any information that can be used to identify you as an individual, including your: full name; address; online contact information; telephone number; any persistent identifier that can be used to recognize you over time and across different services; precise geolocation information; third-party website login information; Financial Information; and any information about an individual linked to such identifying information.
“Financial Information” is a subset of Personal Information that includes the portfolio information you provide to us, or any loan, investment, or portfolio information we receive through Application Protocol Interfaces (“APIs”) connecting to our Site, and your portfolio notes.
When you register on the Site
We collect important Personal Information, such as your name and email, when you register and create an account on our Site (whether for yourself, or on behalf of another individual). We use this information so that we can administer, manage and correspond with you about your account, to improve and personalize our Site and services, and to contact you with information or issues relating to a transaction. We may add your email address to our company mailing list, which informs you of upcoming events, notices, or other material that may be of interest to you.
In order for you to make a payment or complete a transaction on our Site, we may collect your account information, security codes, your address, phone number, email address, usernames and passwords to certain third party sites, and any other information that may be required to process your transaction. This information is used only to facilitate or process your payments and transactions.
When you choose to invest
When you choose to invest using NSR Platform, we will collect the Personal Information and other information we collect from all members, as described above. In addition, we will collect your home mailing address and telephone number. We may also, if we deem necessary, collect your social security and other tax, government, or professional identifiers. We collect this information in order to verify your identity, to enable to appropriate transfer of funds or complete transactions, and to create an internal investor profile. Social security, tax, or other government and professional identifiers are collected for internal use only.
APIs, Investment Advisors, and Custodians
Our Site is designed to operate in conjunction with multiple investment platforms and help investors leverage market data to make informed investment decisions. Therefore, many of our core features require access to information hosted and provided by third parties in order to function.
We may obtain access to the information provided by APIs of Prosper, Lending Club, or other third party sites. We may, therefore, have access to your and, if you are investing on behalf of another individual, that individual’s name, address, or other Personal Information—including sensitive Financial Information. We use this information to enable and execute the key features of our Site, such as back testing, portfolio analysis/monitoring, defining investment strategies, and trading.
By linking your third party account to NSRi via API, you consent to NSRi’s access to the information provided by that API, and represent that you have the necessary authority to grant us access to this information. We strongly encourage that you use two-factor authentication if you allow our Site to access any Personal and Financial Information through third-party APIs. We may aggregate and analyze information provided through these APIs so that we may better understand how users interact with the Site or to otherwise analyze and improve our service offerings.
Please note, we may receive access to your Personal Information or Financial Information as a result of a contract between you and a third party, such as an investment advisor, from appointees such as financial custodians or trustees, or as a result of other contractual arrangements. Except as provided in an Additional Agreement, all information provided to NSRi will be treated in accordance with this Policy.
When you contact us through the Site
On our Site, we request your name and email address if you contact us through our ‘contact us’ forms. We will use this and other information collected through the contact forms only to correspond with you regarding you inquiry, or as otherwise necessary within the context of your request.
If you sign up for our newsletters or emails
We may offer newsletters and other communications that provide information about our service, company, partners and sponsors, or other information we think would be of interest to you. To opt- in to receive our newsletter, you may sign up using the registration form on the Site and provide your email address and any other Personal Information required by the online form. By providing this information, you consent to our collection of the Personal Information you provide to us, and the use of that Personal Information in accordance with this Policy.
Third party sites and services
Certain services on our Site—such as video hosting—are provided by third parties. You may also visit other third party sites through links on our Site. These third parties are not bound by this Policy and may have privacy policies of their own governing the use and disclosure of your Personal Information. Please read any policies of third parties before you provide Personal Information to them. We do not have control over the information hosted on or provided by third party APIs and we are not liable for unauthorized collection, use, or disclosure of information by our third party API partners.
3. With whom may we share your Personal Information?
We value our customers’ Personal Information and do not sell access to our customer lists. We do not share your Personal Information with unaffiliated third parties except as necessary to complete a transaction or request. For example, we may, as part of our investing and portfolio monitoring responsibilities, share Personal Information with a relevant service provider to the extent necessary to authenticate or complete a transaction, or as otherwise necessary execute these functions. We reserve the right to share your Personal Information with our current or future affiliates, subsidiaries, parents and partners who agree to abide by this policy.
We may, without your consent, share Personal Information with service providers who provide certain services on our behalf, or in the other circumstances noted below. For example, we may share certain Personal Information we collect with third parties such as providers of data hosting or processing services, payment processors, or other service providers. We reserve the right to share any information we possess or data derived from it, provided such information has been reasonably de- identified.
In limited circumstances, we may share Personal Information we possess as part of a sale or transfer our business, or substantially all of our assets. We may also share Personal Information if we need to protect the interests of our customers, to the extent allowed by law. Similarly, we may share Personal Information with governmental authorities or otherwise in response to a legal request that we believe requires us to do so. We will share any such information to the extent we believe that request requires. Legal requests include, for example, search warrants, subpoenas, and other court orders. We may also receive legal requests or orders from jurisdictions outside the United States, in which case you consent for your Personal Information to be transferred to the applicable country.
4. What choices do I have about the collection, use, and disclosure of my personal or other information?
It is possible for you to use our Site without providing any Personal Information, but you may not be able to register or access many of our features. Furthermore, you may opt out of marketing communications from us. Please note, if you do not wish for us to provide certain information to one or more of our service providers, we may be unable to complete a transaction you request. You can unsubscribe from all email newsletters or similar communications by clicking on the unsubscribe link provided in every email. You may opt out of all information sharing with third parties for marketing purposes by contacting us at the address or email below.
5. How can I access or update my Personal Information?
We ask that you keep current any Personal Information and any account information. You may access and modify this information. We strongly suggest that you regularly update your password and activate two-factor authentication.
You may also access or update any Personal Information we hold about you by sending a letter or email using the contact information listed below. We will respond to reasonable requests for access or revision and will provide access to the extent required or allowed by law. However we may decide not to grant access or make revisions where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in any given case, or when the rights of others would be violated by granting the access.
Please note, we may not have the authority to provide access to or modify information hosted or provided by our third party API partners. If you wish to access, update, modify, or remove such information, you may need to do so directly through that third party.
To obtain a list of the Personal Information that NSRi holds about you, or for residents of California (as required by California law) the personal information NSRi has disclosed about you to third parties for direct marketing purposes during the preceding calendar year (if any) please send a written, signed request to the address below.
6. Cookies and online tracking.
Please note, most modern browsers include a “do not track” feature that may help protect your privacy. However, because there is not yet a defined response to do-not-track requests, our Site does not respond to your browser’s do-not-track request.
7. Is my Personal Information protected?
We use reasonable security measures to protect any Personal Information held by NSRi. We implement and regularly review various physical, procedural and technological safeguards that we believe will keep your Personal Information secure. We provide—and strongly encourage users to use—two-factor authentication as an additional security measure.
8. International guests
9. Minor Users and COPPA
NSRi complies with the Children’s Online Privacy Protection Act (“COPPA”). This site is neither directed at nor intended for minors under the age of 18. In the event that we have inadvertently collected Personal Information from a user under age 13, we will promptly delete it, in compliance with COPPA. Do not use this Site if you are under the age of 18.
10. Limitation of liability
By providing us with any Personal information you expressly and unconditionally release and hold harmless NSRi, its parents, subsidiaries, affiliates, related companies and their respective shareholders, owners, members, directors, officers, employees and agents (collectively, the “Releasees”) from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your collected Personal Information. In addition, while we take reasonable steps to prevent third-party companies from making unauthorized use of your personal information, we cannot be held liable for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your collected Personal Information by those third parties.
11. Changes to this policy
This policy may change from time to time. We will post the most current version of this policy on our website with the effective date. Your continued use of the website means you consent to the terms of any new Policy.
12. Contact Us
Attn: Summer Tucker
1416 Larimer Street, Suite 203
Denver, CO 80202
We’re here to help. Give us a call at 720-259-0455 or Chat with us.