Privacy Policy

ONRAMPINVEST, LLC PRIVACY POLICY

This Privacy Policy explains how Onramp Invest, LLC (“Onramp,” “we, ”or “us”)collects, uses, and discloses information about you. This Privacy Policy applies when you use our website, log in to our investor platform (the “Investor Platform”), log into to our advisor platform (the “Advisor Platform”),otherwise use other online products and services that link to this Privacy Policy (collectively, our “Services”), engage with us on social media, or otherwise interact with us.

This Privacy Policy applies to a user of the Investor Platform (an “Investor User”) and a user of our Advisor Platform (an “Advisor User”). Advisor Users are employees or agents of companies who are investment advisors on the Advisor Platform (an “Advisor”). Investor Users and Advisor Users are referred to collectively and individually as “users” or “you” in this Privacy Policy.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Please note that at this time our Services are intended for users in the United States only. Should the geographic scope of our Services expand in the future, we will update our Privacy Policy accordingly. If you are an Investor User, please further note that our relationship is with your investment advisor and you should consult your investment advisors before using our Services.

CONTENTS

Collection of Information

Use of Information

Sharing of Information

Advertising and Analytics

Transfer of Information to the United States and Other Countries

Links to Other Websites

Your Choices

Children

Do Not Track Notice

Information Retention Contact Us

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us.

The types of information we may collect include:

•                     Basic User Information: We collect information necessary to create your account and provide you the Services. For Investor Users, we collect information such as your name, email address, postal address, phone number, birth date, Social Security Number, gender, photo identification (such as passport or driver’s license), information contained in a utility bill, bank account number, routing number, and any other information you choose to provide. Advisor Users may be asked to provide their name, email address, firm or company name, phone number, and payment information in connection with use of our Services. [Any financial information provided by Advisor Users [and Investor Users], such as [payment method (valid credit card number, type, expiration date or other financial information), bank account and routing number] is collected and stored by our third party payment processing company, and use and storage of that information is governed by the third party payment processor’s applicable terms of service and privacy policy.]

•                     Information You Provide to Us: We collect information that you provide to us about yourself and about others such as (a) information about Advisors, Advisor Users and Investors Users, (b) any feedback or suggestions you provide to us about our Services, and (c) any other information you choose to provide to us.

Information We Collect Automatically When You Interact with Us

When you access or use our Services or otherwise transact business with us, we may automatically collect certain information, including:

●    Activity Information: We may collect information about your activity on our Services.

●    Transactional Information: For Advisor Users, when you subscribe to our Advisor Platform, we may collect information about your subscription sign-up, such as the date and location of the transaction.

●    Device and Usage Information: We may collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We may also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.

●    Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.

Information We Collect from Other Sources

We obtain information from third-party sources. For example, if you are an Investor User we may collect information about you from your investment advisor. Additionally, if you create or log into your Onramp account through a third-party platform (such as Twitter), we may have access to certain information from that platform, in accordance with the authorization procedures determined by such platform.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain services based on your browsing behavior.

USE OF INFORMATION

We use the information we collect to provide our Investor Platform and Advisor Platform, display crypto asset values to Advisors, execute trades initiated by Advisors on behalf of Investor Users, display a transaction log for such trades, and for internal business purposes, such as operations or analysis. We also use the information we collect to:

●    Provide, maintain, and improve our products and services;

●    Process transactions and send you related information;

●    Personalize and improve your experience on our Services;

●    Send you technical notices, security alerts, and support and administrative messages;

●    Respond to your comments and questions and provide customer service;

●    Communicate with you about products, services, and events offered by Onramp and others and provide news and information thatwe think will interest you (see the Your Choices section below

for information about how to opt out of these communications at any time);

●    Monitor and analyze trends, usage, and activities in connection with our Services;

●    Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);

●    Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Onramp and others;

●    Debug to identify and repair errors in our Services;

●    Comply with our legal and financial obligations; and

●    Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

●  We may share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with webhosting, cloud storage, payment processing, fraud prevention, customer service, and marketing and advertising.

●  If you are an Investor User, we share certain information with your investor advisor with whom you interact;

●  If you are an Investor User and elect to use our Services, you will have a cryptocurrency custodial account to Prime Trust, Equity Trust or Gemini. We encourage you to read the applicable privacy policies and terms and conditions of such partners or websites [before opening an account with them].

●  We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

●  We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Onramp, our users, the public, or others.

●  We may share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

●  We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

●  We may share personal information between and among Onramp and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.

●  We share personal information with your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

ADVERTISING AND ANALYTICS

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Onramp and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

TRANSFER   OF  INFORMATION  TO  THE        UNITEDSTATES AND OTHER COUNTRIES

Onramp is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

LINKS TO OTHER WEBSITES

Our Services may contain links to other websites, including third party investment websites; however, this Privacy Policy only addresses our use and disclosure of your information. If you choose to link to an external website from our Services, you will leave our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites. We encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.

YOUR CHOICES

Account Information

If you are an Investor User, your investment advisor may update and correct certain account information displayed to you on a dashboard through our Investor Platform. Investor Users and Advisor Users may also contact us below to update or correct certain account information. If you wish to delete your account, please contact us, but note that we may retain certain information as required by law or for our legitimate business purposes.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications Preferences

You may opt out of receiving text messages or promotional emails from Onramp by following the instructions in those communications or contacting us below. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

CHILDREN

This website is not intended for or directed at children under the age of 13. In addition, we do not knowingly collect personal information from children under the age of 13. Only adults 18 years or older are permitted to access this website and provide their personal information to us.

DO NOT TRACK NOTICE

This website does not currently support certain browser settings or otherwise respond to Do Not Track requests.

INFORMATION RETENTION

The personal information we collect about you will be retained for the time required to fulfil the purposes for which it was collected and processed, including for the purpose of satisfying legal, business, professional, contractual, regulatory, accounting or reporting obligations.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at legal@onrampinvest.com.

Onramp © 2021. All rights reserved.