Updated: December 10th, 2024
At Caplight Technologies, Inc. (the “Company”), your privacy is very important to us. We
also value transparency and want to be clear about how we collect, use and share
information about you.
This policy is here to help you understand:
- The categories of information we collect about you
- How we use information we collect
- How we share information we collect
- How we store and secure information we collect
- Other important privacy information
This Privacy Policy applies to you when you access or use any domains or subdomains of
Caplight’s website at https://caplight.com/ (the “Site), or when you access, use, or
download any other products, services, features, content, widgets, materials or other tools
offered by the Company or its subsidiaries and affiliates, including Caplight Markets LLC
and Caplight special purpose entities, organized from time to time (collectively the
“Services”). “Caplight”, “we”, “us”, and “our” refer to the Company together with any of our
subsidiaries and corporate affiliates. For more information about our Terms of Use, please
click here.
We collect the categories of personal information listed below:
- Directly from you when you provide the information to us,
- Indirectly from you when you use or access our Services, the Site, and
- From other sources like third-party service providers and partners.
Information you provide to us
We collect information from you when you input it or otherwise provide it directly to us.
Account Information: We collect information about you when you create an account or sign
up for Services. For example, you provide your name, email address, password, and phone
number when you create an account. You also select whether you are a signing up as an
investor or a shareholder. Depending on the Services you select, you provide your address,
date of birth, and taxpayer ID, such as a social security number or other government issued
ID number. We collect this information to verify your identity and to help the government
fight the funding of terrorism and money-laundering activities, as required by US law. If you
register or use the Services through third-party sites or applications, such as Google, we
may gather information from them.
Bank, Brokerage and Other Payment Information: To transact with us, you may invest in a
Caplight special purpose entity. You provide your banking information, including bank
account and routing number and any other payment information, to the manager
designated for that entity. You may provide the manager your brokerage information to
enable the manager of the special purpose entity send you shares following the exit event.
Buyer Information: To make investments with Caplight’s special purpose entities, when you
sign up for Services, you provide us information concerning whether you are investing on
your own behalf or that of an institution, your status as an accredited investor, your
investment objectives, risk tolerance, investment time-horizon, investment experience, and
information concerning your income and/or net worth. You also provide certain commercial
information and information about your investment preferences, which become a part of
your investor profile, and may include how much you anticipate investing in certain asset
classes, your target investment size per investment, the asset classes you have invested in,
and sectors of interest.
For investments related to some issuers, you may also provide us employment information
or representations that you are not affiliated with, or employed by, a competitor of that
issuer. If you express interest in investing in a particular investment opportunity, you
provide us information about your interest and preferences which may include the
investment amount and other information regarding your interest in making an investment.
Seller Information: To sell private company equity through a Caplight special purpose
entity, you provide us information and documents concerning your ownership of shares or
options. For example, you provide information about the company in which you own the
shares, ownership type, and the number of shares you want to sell. If you are a seller, you
also provide us information and documents reflecting your vesting and other attributes
applicable to your shares or options. You may also be asked to provide your spouse’s name
and email address if you are married. You also provide information about your preferences,
such as, for example, the price at which you desire to sell your shares.
Support Information and Other Communications: The Services include customer support,
where you may choose to submit information or questions concerning a problem you are
experiencing with a Service or questions you have about a Service. You may also provide, or
be asked to provide, screenshots, documentation or information to help us address your
problem or respond to your question.
You may also provide us with feedback and survey responses when using the Service, as
well as other information you voluntarily provide to us when communicating with us, such
as via email, or via other actions you perform when using the Services.
Trust Information: If you purchase or sell securities held in the name of the trust, you
provide us with additional information and documents concerning the identity and contact
information of individuals related to the trust.
Verification Information and Documents: If required to help us verify your identity, you may
provide us a copy of your driver’s license, passport or other government issued ID. If required to help us verify your residence,
you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank
statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti-money
laundering, US Treasury department rules or regulations or other legal requirements. By
providing the verification information and documents mentioned above, you also provide us
information within those records, which may include characteristics of protected
classifications like your sex, age, national origin, and citizenship status.
Transaction Information: We collect information in connection with the transactions you
become a party to through our Services as either a seller or a buyer (“Transaction Data”).
Transaction Data includes, without limitation, the terms on which you purchase or sell
securities and information relating to price, size, volume, class of securities, bids, offers,
transfer restrictions, and any derivative data related thereto.
Information we collect when you use the Services
We collect the following categories of information about you when you use our services,
including when visiting the Site and taking certain actions within the Services.
Information About Your Use of the Services: We collect certain information about you when
you visit the Site and interact with any of our Services. We use third party software to
monitor and record user interactions with our website. These track mouse movements,
clicks, form inputs and general site navigation.
Device and Connection Information: We collect information about your computer, phone,
tablet or other device you use to access the Services. This device information may include
your operating system, browser type, IP address, URLs of referring pages, location, and
device identifiers.
Cookies, Web Beacons, Pixel Tags and Other Similar Technologies: Caplight and its third-
party service providers, such as our analytics and advertising partners, collect certain
information using cookies, web beacons, pixel tags and other similar technologies to
provide functionality, enable and support security features, recognize you across different
devices, improve our offerings, understand how you use and interact with our Services,
improve performance of Services, and otherwise manage and enhance Services. “Cookies”
are simple text files stored on your device for use by a browser. “Web Beacons” or “pixel
tags” are small images, often transparent, on a website or email that are used to observe if
you have accessed content. Using cookies, web beacons or pixel tags, or other tracking
technologies are standard practices on internet web sites.
Some web browsers transmit “do-not-track” signals to websites. At this time, our Services
are not designed to respond to these signals or similar mechanisms from browsers.
We use session cookies to make it easier for you to use our Services and to identify you
while you are on the Site or Application. We also use persistent cookies to make it easier for
you to navigate the Site and track whether you are logged into the Site. A persistent cookie
remains on your device’s hard drive for an extended time. You can remove persistent
cookies by following the directions provided in your internet browser’s “help” file. If you reject persistent cookies,
you will still be able to view the Site, but your ability to use some areas of the Site, such as
automatically-generated recommendations, will be limited.
Information we receive from other sources
We receive information about you from third-party services and business partners.
Third-Party Identity Verification Service Provider: We receive information about you from a
third-party identity verification service provider to help us confirm your identity, prevent
fraud, money-laundering and other illegal activity, and to satisfy legal requirements relating
to the Services.
Marketing and Advertising Services and Partners: We receive information about you and
your activities on and off the Services from third-party service providers, such as Google,
RocketReach, Apollo, Datadog, Logrocket, Heap, LinkedIn and other advertising, social
media and market research partners who provide us with information about you, and/or
your engagement with and interest in our Services.
Business Partners: We may receive information about you from our third-party partners,
under referral programs, partnership agreements and/or under joint marketing
arrangements.
We use the information we collect based on the Services you choose to receive. The
specific purposes are described below.
To Provide the Services and Personalize Your Experience: We use information about you to
provide the Services to you, including to process transactions for you, authenticate you
when you log in, verify your identity, and, if you are seeking to invest, determine your
eligibility for investments. We also use information you provide to validate that information,
comply with legal requirements, provide customer support and communicate with you, and
operate and maintain the Services.
We also use information about you to personalize and improve your experience while using
the Services and to determine effectiveness of the Services. We also use information about
you and your activities to provide an integrated experience, such as allowing you to access
the Services from multiple devices.
To Communicate With You About the Services: We use your contact information to send
communications to you (typically via email) about your transactions, including confirming
the terms on which you purchase or sell securities, updating you on the status of
transactions and related deadlines, responding to your questions or comments, and
providing information received from the issuer or, when applicable, other parties to your
transactions. If you are eligible to invest through the Site, we send you notifications about
potential investment opportunities available through the Site. We also provide tailored
communications to you based on actions you take on the Site.
To Operate the Services: We share information about you as needed with our own service
providers, including financial institutions, fund administrators, accountants, auditors,
lawyers, payment providers, information technology staff, advisors and our affiliates. We
only share information to the extent it is required to fulfill our obligations to you and to
regulators, and to operate the Site and the Services.
For Research and Development: We strive to make our Services better, smarter, faster, more
secure and easier to use. We collect information about how people use the Services and
feedback provided directly to us to identify trends and problems, usage and activity
patterns, and areas for integrating and improving our Services. We may also test and
analyze certain new features with some users before rolling out the features to all users.
To Market, Promote and Drive Engagement With the Services: We use your contact
information and information about how you use the Services to send promotional
communications that may be of interest to you, including by email and by displaying our
content on other websites and applications, such as on platforms including Google or
Facebook. These communications are intended to increase engagement and what you get
out of the Services, including information about new features, new content, and events we
think may be of interest to you. We also communicate with you about new products and
services and promotions.
We do not – and do not plan to – rent or sell personally identifiable information about you
to other people or to non-affiliated companies.
For Safety and Security: We use information about you and your Service use to verify your
identity, accounts and activity, to monitor suspicious or fraudulent activity, and to identify
violations of Service policies. We also use your information to debug, identify and fix errors
that impair how our Services function.
As Required by Law or Regulations: We retain information about you that is required by US
law or regulation, including those applicable to the sale of securities or operating an
investment advisor or broker-dealer. In general, we are required to retain these records for
at least three years, and up to six years (and in some circumstances, longer). We may keep
some information longer to meet our needs and those of our customers, even after you
close or deactivate your account, including for backup, archives, contract enforcement,
dispute resolution. We may access and disclose information about you with US, state or
international regulators where we believe doing so is required or appropriate to comply with
laws, regulations or other legal processes or law enforcement requests, such as court
orders or subpoenas.
For a Merger, Sale or Other Asset Transfer: If we are involved in a merger, acquisition,
financing due diligence, reorganization, bankruptcy, creation of a trust or other affiliated
entity, receivership or sale of Caplight’s assets, or other corporate transaction affecting
Caplight, your information may be shared, transferred or sold under a duty of confidentiality
as part of a transaction as permitted by law or by contract.
Legal Bases for Processing (for EEA users): If you are an individual residing in the European
Economic Area (“EEA”), we collect and process information about you only where we have
legal bases for doing so under applicable EU laws, including the General Data Protection
Regulation (“GDPR”). The legal bases depend on the Services you use and how you use
them. This means we collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, perform a
contract with you, take necessary steps prior to performing a contract or at your
request, provide customer support, and to protect the safety and security of the
Services;
- It satisfies a legitimate interest (which is not overridden by your data protection
interests), such as for research and development, to market and promote the Services,
to personalize services you receive, and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal requirement.
If you have consented to our use of information about you for a specific purpose, you may
change your mind at any time, but this will not affect any processing that has already taken
place. Where we are using your information because we or a third party (e.g. your
employer) have a legitimate interest to do so, you may object to that use though, in some
cases, this may mean no longer using the Services.
To do so, please email us at contact@caplight.com
We manage a private company equity and equity derivatives marketplace, and we want it to
work well for you. This means sharing information through the Services and with certain
third parties. We share information we collect about you with third parties in the ways
discussed below, including in connection with possible business transfers.
With Affiliates of Caplight: If you are a party to a prospective or actual transaction, we share
information about you with our affiliates, including our broker-dealer, Caplight Markets LLC,
to provide you Services relating to that transaction.
With Parties to a Transaction, Companies and Service Providers: If you are a party to a
prospective or actual transaction, we will give the other party (or other parties) to the
transaction the information they need to evaluate and enter that transaction. If you enter
into a transaction with a third-party company, such as by becoming a shareholder, that
company will receive information about you subject to its own privacy policy, and may be
required to disclose that information to its own board members, officers, investors or
shareholders.
We also provide your information where necessary for a transaction or to comply with legal
requirements. For example, we may provide certain aspects of your information to financial
institutions, payment processors, fund administrators, accountants, auditors, lawyers,
payment providers, third-party hosting service, email and technology service providers, information
technology staff, advisors, affiliates, marketing and analytics partners, or third-party verification services.
As part of providing their services to us, our marketing and advertising service providers
mentioned above may use cookies and other technologies to collect data on our users’
behavior and their devices. This may include, for example, a device's IP address, device type
(unique device identifiers), browser information, and geographic location (region and/or
country only).
We do not and will not sell your personally identifiable information. We also do not offer
financial incentives, preferential service agreements, or any other differences in our prices
or services in exchange for your personal data.
We may share aggregated, deidentified and/or anonymized information that does not
specifically identify you or any individual user of our Services for any purpose with any third-
parties, including but not limited with advertisers, national industry organizations, and
prospective affiliates, or as permitted or required by law, or to protect our rights.
When you visit or log in to our website, cookies and similar technologies may be used by our online
data partners or vendors to associate these activities with other personal information they or
others have about you, including by association with your email or ip address. We (or service
providers on our behalf) may then send communications, sales materials and marketing to these
email or ip addresses. You may opt out of receiving this advertising by sending an email to_
unsubscribe@caplight.com _or using an “unsubscribe” link at the bottom of our communications
piece.
With Regulators: We may share information about you with US, state or international
regulators where we believe doing so is required or appropriate to comply with any laws,
regulations or other legal processes or law enforcement requests, such as court orders or
subpoenas.
We may also share information about you to protect the security and integrity of our
Services, to protect Caplight’s interests, or those of other persons or the public.
With Business Partners: We may share information about you with our third-party partners
under referral programs, partnership agreements or under joint marketing arrangements.
With Third-Party Sites: The Site may contain links to third party web sites and may redirect
you to third party web sites ("Third Party Sites"). These sites include, among others, service
providers who have a relationship with the Company. Third Party Sites are not under our
control, and we are not responsible for any Third Party Sites, or the accuracy, sufficiency,
correctness, reliability, veracity, completeness, or timeliness of their information, links,
changes or updates. The inclusion or access to Third Party Sites does not imply an
endorsement thereof by the Company, or of the provider of such content or services, or of
any third party web site. The Company reserves the right to terminate any link or linking
program at any time. Please be aware that when you enter a third party web site, any
information you provide, including financial information, is subject to the terms of use and
privacy policy of that site.
With Your Consent: We share information about you where you have given us consent to do
so for a specific purpose. For example, we may disclose information to your financial
advisor, accountant attorney or spouse, or other individual or company you authorize to
receive information about you.
Business Transfers: We may share or transfer information we collect under this privacy
policy in connection with any merger, sale of company assets, financing, or acquisition of
all or a portion of our business to another company. You will be notified via email and/or a
prominent notice on the Services if a transaction takes place, as well as any choices you
may have regarding your information.
We take steps to ensure that your information is treated securely and in accordance with
this policy. While we use industry-accepted security principles, practices, and tools, the
internet is not 100% secure and we cannot ensure or guarantee the security of data, during
transmission through the Internet or while stored on our systems or otherwise in our care.
We do not accept liability for unintentional disclosure.
By using the Service or providing personal data to us, you agree that we may communicate
with you electronically regarding security, privacy, and administrative issues relating to your
use of the Service. If we learn of a security breach, we may attempt to notify you
electronically by posting a notice on the Service or sending an email to you. You may have a
legal right to receive this notice in writing.
We use a data hosting service provider in the United States to host the information we
collect, and we use technical measures to secure your data. We use industry-accepted
practices, including 256 - bit encryption, to protect customer-related information. Information
is encrypted at rest and in transit from client to web to web server, and to the database.
We request third party service providers to agree to keep your information confidential by
entering into agreements that limit their use of the information they receive about you for
purposes of performing the services for which they are being retained.
If you are outside the United States, by using the Services or visiting the Site, you will
transfer data to the United States and are permitting your information to be used in
accordance with this Privacy Policy.
You have choices and rights available to you when it comes to your information. They are
summarized below.
Your Rights as a California Resident: Residents of California have the right to request from
us, one time per year, certain information with respect to the types of personal information
we share with third parties for those third parties’ direct marketing purposes and the
identities of the third parties with whom the business has shared such information during
the immediately preceding calendar year.
To exercise your rights, please use one of the submission methods mentioned below under
“Submitting Requests Pertaining to Your Information".
Your Rights as a Vermont Resident: We do not share nonpublic personal financial
information we collect about Vermont residents to non-affiliated third parties except for our
everyday business purposes or as otherwise permitted by law. If you wish to revoke any
authorization to share your nonpublic personal financial information, please contact us for
assistance at contact@caplight.com though we will no longer be able to provide you
Services or access to the Site.
If You are a European Economic Area Resident:_** If you are an EEA data subject, you may
review, correct or update the personal data you provide at any time.
If you would like to exercise your GDPR rights, please use one of the submission methods
mentioned below under “Submitting Requests Pertaining to Your Information”.
In the event of a data breach, we will endeavor to notify you within 72 hours of detection of
a breach that we conclude poses significant risks to your rights and freedoms under the
General Data Protection Regulation. You may also lodge a complaint with a supervisor
authority in the EEA member state in which you reside.
Access to Your Data and Documents: You may review, correct or update the personal data
you provide at any time. You may access your documents relating to your transactions at
any time by logging in into your account and navigating to the “My Documents” and the “My
Transactions” section of the Site or Application. If you need assistance, please contact us
at contact@caplight.com.
Unsubscribe Options: If you chose to use the Services, you will receive periodic emails or
other electronic communications from us which, based on the information you provide, may
be of interest. If you no longer wish to receive our communications, you may unsubscribe
by following the instructions included in each communication.
Children’s Privacy: The Site and our Services are not directed to any person under the age
of 18. If you become aware that your child has provided us with personal data without your
consent, please contact us at contact@caplight.com. We do not knowingly collect or solicit
information from, market to, or accept services from children.
Lost or Stolen Information: You must promptly notify us if you become aware that any
information provided by or submitted to the Site is lost, stolen or used without permission.
Changes to this Policy: Each time you visit the Site or use the Services, the current version
of the Policy will apply. When you use the Site, you should check the date of this Policy
(which appears at the top of the Policy) and review any changes since the last version. Our
business changes frequently and this Policy is subject to change from time to time. Unless
stated otherwise, our current Policy applies to all information that we have about you. We
may require you to affirmatively assent to a revised version of this Policy as a condition of
continuing to use the Site or our Services.
Submitting Requests Pertaining to Your Information: If you would like to make a request
regarding your information, you may do so, free of charge, by clicking -
contact@caplight.com You will be redirected to fill out a form with certain information
about your request. *If you have a registered account on the Site or the Application, please
make sure to login to your account before submitting your request.* This will help us verify
your identity.
Please note that for all requests, we will need to verify your identity to confirm that you are
the individual about whom we have collected personal information.
Contact Us: Your information is controlled by Caplight Technologies Inc. If you have any
questions or concerns about how your information is handled you may contact us at:
Caplight Technologies Inc.
53 1 Howard Street
San Francisco, CA 941 05
contact@caplight.com
Feel free to contact us with your questions at contact@caplight.com
Investment opportunities posted on this website are "private placements" of securities that
are not publicly traded, are subject to holding period requirements, and are intended for
investors who do not need a liquid investment. Investing in private companies may be
considered highly speculative and involves a high degree of risk, including the risk of
substantial loss of investment. Investors must be able to afford the loss of their entire
investment.
Caplight Markets LLC (“Caplight Markets”) is a subsidiary of Caplight Technologies Inc.
Caplight Markets is a broker/dealer registered with the Securities Exchange Commission
and is a FINRA/SIPC member firm.
Equity securities and equity derivatives are offered through Caplight Markets. Check the
background of this firm on FINRA’s BrokerCheck.
Caplight.com is a website operated by Caplight Technologies Inc. ("Caplight"). By accessing
this site and any pages thereof, you agree to be bound by our [Terms of Use].
Caplight and logo are trademarks of Caplight Technologies Inc. Other trademarks are
property of their respective owners.
