Last Updated: October 27, 2022
The Coterie.Me, Inc. and its affiliates (“The Coterie,” “we,” “our,” and/or “us”) value the privacy of individuals who use our website and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from or about our users (“Users”) or their devices. The Coterie’s mission is to use technology to build innovative financial products and revolutionize access for a new generation of builders and investors. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service, our financial privacy notice, which describes how our financial institution affiliates may collect, use, and share your personal information, and other disclosures.
Information We Collect
We may collect a variety of information from or about you or your devices from various sources, as described below.
If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.
A. Information You Provide to Us.
Registration and Profile Information. When you sign up for an account, we ask you for your name, email address, phone number, address, title, company, date of birth, username, country of birth, citizenship status, and any other information we collect.
Payment Information. When you add a payment method to your account, we will receive your personal or business financial account information, such as account numbers or wire transfer information.
Other Financial Information. We may also collect:
• Information regarding your status as an accredited investor, a qualified purchaser, and a qualified client, such as your assets, liabilities, employment, income, and expenses that you may provide to us in a certification of your status as such;
• Investment activity information, such as the specific investment opportunities or transactions that you have chosen to participate in; and
• Information regarding your financial situation which permits us to assess your investment objectives.
Government Identifiers. To use our Services and to help the government fight the funding of terrorism and money laundering activities, we may need to collect government identifiers such as your passport number, driver’s license number, social security number, and Tax ID or other government identifiers. We may also ask to see identifying documents, such as a driver’s license or passport. In doing so, we may receive demographic data such as your age, race/ethnicity or national origin, and citizenship status.
Estate Planning Information. If you choose to use our estate planning product, we may ask for additional information to evaluate your interest in estate planning services and help your estate planning lawyer prepare your trust, such as any gift tax exemption previously used, marital or partnership status, information about your spouse or domestic partner, and information about beneficiaries. Please note that these estate planning services will be performed by your estate planning lawyer and at no time is an attorney-client relationship fostered or created with The Coterie through the performance of any such services.
Communications. If you contact us or our affiliates directly, we may receive additional information about you. For example, when you contact our Customer Support Team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. If we offer a newsletter or similar periodic communication and you subscribe, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.
Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. We will collect the information you make available to us on LinkedIn.
B. Information We Collect When You Use Our Services.
Location Information. When you use our Services, we infer your general location information (for example, your IP address may indicate your more general geographic region).
Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, MAC Address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, account name, user ID, and push notification tokens.
Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, purchases you make, and the dates and times of your visits.
Information from Cookies and Similar Technologies. We and third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.
Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
Text Information. We work with a third-party partner to facilitate fraud alert text messages between vendors and our users. We receive information about these communications, such as the date and time of the SMS message, the user’s phone numbers, and the content of any SMS messages.
C. Information We Receive from Third Parties.
Other Users. We may receive information about you, including your contact information, from
existing Users who refer you to our Services.
Our Banking Partner. Our services allow you to open a non-interest-bearing demand deposit account with our banking partner, Blue Ridge Bank, N.A.; Member FDIC. If you do so, you can use our Services to access your deposit account, view information about your deposit account, and conduct certain deposit account transactions. You may also be given access to various features through our Services separate from your deposit account. If you cancel your enrollment in our Services at any time, we may close your deposit account.
Our Services related to your deposit account are also governed by the Coterie Consumer Deposit Account Agreement. Please review this document carefully.
Credit Report and Background Checks. We work with third-party partners who may provide credit reports and perform background checks on users who sign up for our Services, and receive publicly available information.
Other Third Parties. We may receive additional information about you from other third parties such as Carta and other data or marketing partners and combine it with other information we have about you.
How We Use the Information We Collect
We use the information we collect:
• To provide, develop, maintain, improve, and enhance our Services;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you;
• To personalize your experience on our Services such as presenting tailored content;
• To send you text messages and push notifications;
• To facilitate transactions and payments;
• To de-identify and aggregate information collected through the Services and use it for any lawful purpose;
• To verify your identity;
• To assist our banking partner in determining whether to open a deposit account for you or to verify the existence and condition of your deposit account;
• For Estate Planning Information, to evaluate your interest in estate planning services provided by an estate planning lawyer and to assist your estate planning lawyer prepare your trust (The Coterie does not provide estate planning services directly and at no time is an attorney-client relationship fostered or created with The Coterie through the performance of any such services);
• To find and prevent fraud, terrorism, and money laundering activities; and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected.
How We Share the Information We Collect
We may share or otherwise disclose information we collect from or about you as described below or otherwise disclosed to you at the time of the collection.
Affiliates. We may share any information we receive with our corporate affiliates for any of the purposes described in this Privacy Policy. For example, we may share information we collect from or about you with our Affiliates:
• To select and close on transactions in which you have chosen to invest. For example, we use information that you provide to us regarding your interest in a particular offering in order to gauge whether sufficient interest exists to fund a particular investment opportunity.
• To comply with applicable laws and regulations. For example, we use information gathered in your investor questionnaire to help ensure that we are offering our investment opportunities consistent with the requirements of federal and state securities laws and regulations.
• To help us inform you of investment opportunities. For example, we use information about your prior investments to assist us in determining subsequent offerings in which you may be interested.
Transaction Partners and Service Providers. We may share any information we receive with transaction partners and service providers retained in connection with the provision of our Services, including Unit Finance Inc. (“Unit”).
We may share any information we receive in one or more of the following circumstances:
• We may disclose personal information with individuals and entities who are involved with a specific transaction.
• We may disclose personal information about you to third parties for servicing and processing transactions, to comply with the requests or instructions of our regulators, to protect against fraud, for risk control, or to perform services on either your or our behalf.
• We may disclose your personal information to companies that provide services to us, such as our attorneys, accountants, and auditors.
• Unit may assist us in processing transactions, handing deposit account operations, and providing technological connection to our banking partner. In particular, Unit may perform any functions on your deposit account that we are otherwise authorized to perform. Unit’s access and use of your information is governed by Unit’s Privacy Policy, available at https://www.unit.co/clients-privacy-policy.
Your Estate Planning Lawyer. We may share your Estate Planning Information with your estate planning lawyer to facilitate the lawyer’s preparation of your trust. At no time is an attorney-client relationship fostered or created with The Coterie through the performance of any such services.
User Content. Our Services allow users to post messages to other users within the Services and privately message other members. Your name, username, and other profile information will always be viewable and searchable by other users. We are not responsible for the other users’ use of messages you post, so you should carefully consider whether and what to post or how you identify yourself on the Services.
User Referrals. When you refer someone to our Services through our referral program, we let your referral know that you referred them. Likewise, if an existing User referred you to our Services and you sign up for an account and make an investment through our Services, we let the referring User know that you made an investment when they receive credit for the referral through our referral program. If you receive a referral from another User but would rather decline the referral, please contact us via the Contact Information section below.
Marketing. We do not rent, sell, or share information about you with non-affiliated companies for their direct marketing purposes, unless we have your permission.
Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For example, we may be required by law to provide to the federal government information about the identity of our investors, as well as their individual receipts of income and gross proceeds pursuant to Sections 1471-1747 of the United States Internal Revenue Code. For the avoidance of doubt, the disclosure of your information may also occur if you post any objectionable content on or through the Services.
Merger, Sale, or Other Asset Transfers. We may disclose and transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets.
Consent. We may also disclose information from or about you or your devices with your permission, including when you give someone power of attorney or other authorization to act on your behalf.
Your Choices
Financial Information. You have the right to restrict the sharing of personal and financial information with our affiliates (companies we own or control) and outside companies that we do business with. To exercise this right, review our financial privacy notice and fill out, sign, and send back the form on page 3.
Location Information. You can prevent your device from sharing precise location information at any time through your device’s operating system settings.
Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.
User Referrals. If you receive a referral from another User but would rather decline the referral, please contact us via the Contact Information section below.
Third Parties
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
Security
We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.
Children’s Privacy
We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at privacy@thecoterie.me.
International Visitors
Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services 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 for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.
Update Your Information
You can update your account and profile information through your profile settings.
Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at privacy@thecoterie.me or write to us at The Coterie, 77 Geary Street, 5th Floor, San Francisco, California, 94108
