Updated September 1, 2015
WE RESPECT YOUR PRIVACY
We are committed to protecting your personal and financial information.
INFORMATION WE COLLECT
When you interact with us through the Site or Services, we may collect and process Personal Information and other information from you, as further described below:
We collect Personal Information when you voluntarily provide such information such as when you (i) register for access to the Services (for example, contact information such as your name, email address, phone number, mailing address); (ii) complete certain forms on the Site; (iii) upload or submit any material through the Site, (iv) request any information or contact us with inquiries; or (v) wish to use certain Services. This Personal Information is required to transact business, to communicate with you, verify your identity and fulfill legal and regulatory requirements.
When you visit the Site or interact with Sphere through the Site or Services (and whether or not you register for access to the Services), we receive, automatically track and store certain non-identifying information about you, including but not limited to:
- Device, operating system and browser type;
- IP address;
- language preference;
- cookies; domain servers;
- URL traffic to, through and from the Site;
- statistical information about behavior of visitors/users to the Site; and
- any other web site usage information that we may collect when you visit the Site.
This non-identifying information, which may be collected passively using various technologies or through other means, cannot be used to specifically identify you. Sphere may store such information itself or such information may be included in databases owned and maintained by Sphere affiliates, agents or service providers. The Site may use such information and pool it with other information for administrative purposes, to assess the usage, value and performance of our products and services, to improve your experience with the Services.
Sphere reserves the right to conduct research on its Users’ demographics, interests and behavior based on the Personal Information and other information provided to Sphere. Sphere further reserves the right to disclose aggregated user statistics in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes.
Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent this or to notify you each time a cookie is sent. By blocking or deleting cookies used on our Site or Services, please note that you may not be able to take full advantage of our Services and speeds for the Services may be affected.
USE OF YOUR PERSONAL INFORMATION
- identify you when you sign-in to your account;
- enable us to provide you with the Services;
- send you information we determine you may find useful or which you have requested from us;
- present projects or opportunities to you when you use the Services which we believe will be of interest based on your geographic location and your previous use of the Services;
- administer your account with us;
- enable us to contact you regarding your questions;
- analyze the use of the Services and the people visiting to improve our content and Services;
- use for other purposes that we may disclose to you when we request your information.
- Also, if you provide Personal Information to obtain access to the Services, we will use your Personal Information to provide you with access to such services and to monitor your use of such services. We also may obtain information about you from third party sources to verify your identity so we can properly process your requests and prevent fraud.
Sphere and its subsidiaries and affiliates may also use your Personal Information and other non-identifiable information collected through the Site (collectively, “User Information”) to, among other things, improve user experience, customize content for our users to make the Site more efficient to use, and to help us identify any other issues with respect to the Services or a User’s use of the Site or Services. Sphere and its subsidiaries and affiliates may also use this information to communicate with you regarding the Services.
If you object to our collection or storage of any User Information mentioned above (and any additional information we may choose to gather) you should not use the Site.
While Sphere limits the sharing of your Personal Information and strives to keep your Personal Information private and confidential you acknowledge and agree that as a condition precedent to Sphere providing the Services, we must share some Personal Information with certain third parties as follows.
Tobin & Company Securities LLC (“Tobin”), a North Carolina limited liability company, is a securities broker-dealer registered with the U.S. Securities and Exchange Commission and a member of the Financial Industry Regulatory Authority, Inc. They are a provider of execution and other services related to our securities transactions, and individual personnel of Sphere are registered representatives of Tobin. Tobin is located at 112 South Tryon Street, Suite 1760 Charlotte, NC 28284, tel: 704–334–2772; www.tobinandco.com.
Tobin will perform executions and other services related to our securities transactions, and your Personal Information must be shared with Tobin in order to complete any such securities transactions. You understand and agree that since we do not have direct control over the policies and practices of Tobin, that Tobin shall be solely responsible for maintaining your Personal Information in accordance with its own privacy practices. In connection with Tobin’s own suitability inquiries, the Users involved with certain investment opportunities sometimes require that we or our affiliates provide them with the names, investment amounts, and other information (including social security numbers or other identifying information) regarding investors participating in those investment opportunities.
Sphere works 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 carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing, reporting, tax documentation, and 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 perform other specific services, like collections. Our partners are legally required to keep your information private and secure.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of 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 services, or to protect the rights, property or personal safety of Sphere, its users, issuers, or others.
We may disclose your Personal Information when such disclosure is required or appropriate pursuant to laws, court orders or securities regulations, including responding to court orders and subpoenas, cooperating with government agencies, other regulatory bodies and law enforcement officials, performing background checks, resolving disputes or performing risk-management functions.
We may make certain automatically collected information about your interactions and activities on the Services, such as the business or investment areas of interest to you or you have invested in, and your past activities, projects or proposals, publicly available on or through the Services. Any such publicly available information will be accessible by other Users.
In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
Regarding email contact with and from Sphere, please keep in mind the following: (i) we will send you email relating to your personal transactions; (ii) you will receive certain email notifications (forwarded messages, etc.) for which you may opt-out; (iii) we may send you service-related announcements on rare occasions when it is necessary or proper to do so; (iv) if you email us directly, we may email you back and keep records of all correspondence; and (iv) we may send you emails from time to time letting you know about special promotions, featured investments and other Sphere news. It is your responsibility to ensure that you maintain a current email address with Sphere, and notify us if there are any changes.
SAFEGUARDING USER INFORMATION
The Security of your User Information is important to us, and we take commercially reasonable steps to safeguard such information. These steps and procedural safeguards are in line with industry standards and practices and include:
- Encryption and authentication tools to maintain the confidentiality of User Information including secure socket layer technology (SSL);
- Limits on, to the greatest extent possible, who or what can access your User Information; and
Please note that Sphere cannot ensure or guarantee the security of your User Information nor do we make any representation or warranty regarding the security of your account. If we learn of a security systems breach, then we will use commercially reasonable efforts to attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Site and the Services 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 are solely responsible for helping us to maintain the accuracy and completeness of your personal and other information. We urge you to review your information regularly to ensure that it is correct and complete. If you believe that any of your information is incorrect, please contact us at support@Sphererealtycapital.com.
You may, of course, decline to share any or all of your Personal Information with us or ask us to delete your Personal Information from our systems at any time, in which case we may not be able to provide to you some of the features and functionality found on or through the Site and the Services.
We will retain your User Information for as long as your account is active or as needed to provide you services. You may modify or delete the Personal Information you have provided to us by logging in and updating your account. We may, however, retain certain information as required by law or for necessary business purposes.
QUESTION OF HARM
We may reveal your information to attorneys, private investigator organizations or law enforcement agencies if we believe (i) that you are in risk of harm from another, (ii) that you are harming or interfering (or will harm or interfere) with others, or (iii) that you are violating (either intentionally or unintentionally) our Terms and Conditions of Use or are otherwise violating legal rights.
The Services may be accessed and/or used by Users located outside 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 and by providing your Personal Information on or through the Services you consent to that transfer.
Due to federal law, we do not allow individuals who we know are under 18 years old to participate in our site or services. You must be at least 18 years old to use our site and services. Please understand that we cannot necessarily tell if a user is providing us with his or her true age.
OTHER TERMS AND CONDITIONS
Your access to and use of the Services and this Site is subject to the Terms of Service.