Privacy Policy

Last Updated: 02/03/2019

Privacy Policy

 

Who We Are

Accredify Inc. DBA Investready (‘InvestReady’ or ‘we’ or ‘us’ or ‘our’) gathers and processes your personal information in accordance with this privacy notice and in compliance with the relevant data protection regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

 

InvestReady’s registered office is at 1395 Brickell Ave, STE 800, Miami FL 33131 and we are a corporation registered in Florida under company number P15000054559. We act as both the data controller and data processor when processing your data. We have appointed a representative and internal data protection officer ("DPO") for you to contact if you have any questions or concerns about Groove’s personal data policies or practices.

 

You can reach out to our Data Protection Officer at dpo@investready.com.

 

Information That We Collect

InvestReady processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

 

The personal data that we collect from you is: -

  • Name
  • Date of Birth
  • Primary Residence Address
  • Email
  • Telephone Number
  • Social Security Number (only for certain verification types)

 

We collect information in the below ways: -

  • Online forms
  • Paper/PDF forms submitted via the internet
  • Electronically from data providers authorized by you

 

How We Use Your Personal Data

InvestReady takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.  The purposes and reasons for processing your personal data are detailed below: -

 

  • We collect your personal data in order to verify your accredited / qualified (or jurisdictional equivalent) investor status.
  • We store your personal data to maintain your status certificate available during the timeframe that it is active and to allow for simple re-verifications
  • We only share your personal data with partners to whom you have given us permission. Your online certificate is not indexed or searchable and can only be found using the unique URL link to it.

 

Your Rights

You have the right to access any personal information that InvestReady processes about you and to request information about: -

  • What personal data we hold about you
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from you, information about the source

 

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

 

In line with GDPR enforcement of the right to be forgotten, InvestReady allows you to request account deletion. Simply email us at dpo@investready.com with your deletion request and we will honor your request (InvestReady reserves the right to refuse permanent deletion for a legitimate reason, including applicable regulations and potential audits). Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

 

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. InvestReady uses third-parties to provide the below services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

 

TransUnion

We use TransUnion to run soft-pull credit inquiries in conjunction with our net worth verifications as required by SEC regulations. Their privacy policy can be found here.

 

IRS

We use the IRS IVES program to request income transcripts for some of our income verifications. Their privacy policy can be found here.

 

Mailchimp/Mandrill

We use Mailchimp/Mandrill as our automated email provider to send you welcome emails and alerts about pending or expiring verifications. Their privacy policy can be found here.




GrooveHQ

We use GrooveHQ as our email support program and use it to contact users about support issues. Their privacy policy can be found here.

 

Safeguarding Measures

InvestReady takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including SSL, TLS, encryptions, restricted access, IP filters, IT authentication, firewalls, anti-virus/malware, and two-factor authentication.

 

Transfers Outside the EU (if applicable)

InvestReady utilizes some products or services (or parts of them) that may be hosted/stored in the United States of America, which means that we may transfer any information which is submitted by you through the website outside the European Economic Area ("EEA") for the below purposes: - website hosting & email servers.

 

Therefore, when you use our website, the personal information you submit may be stored on servers which are hosted in the United States. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by InvestReady to protect your data and comply with the relevant data protection laws.

 

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to InvestReady, however, as this information is required for us to provide you with our services, we will not be able to offer our services without it.

 

How Long We Keep Your Data

InvestReady only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We keep your basic information on file as long as you have an account with us and will delete your data when you close your account with us, although we may keep your verification history on our system for up to 5 years for SEC auditing purposes.

 

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

 

Changes and updates to the Privacy Policy

 

As InvestReady changes from time to time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason. We will inform You about that change by sending to You an email. Remember to check our Privacy Policy website.




Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@InvestReady.com or write us at: 1395 Brickell Ave, STE 800, C/O InvestReady, Miami FL, 33131.

 

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@InvestReady.com.

 

Lodging A Complaint

InvestReady only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.

 

InvestReady

1395 Brickell Ave, STE 800

Miami, FL 33131

800-208-5819, dpo@investready.com