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Privacy Policy

Dated May 11, 2021

IMA Creative LLC, IMA Investor LLC, IMA SPAC LLC, and affiliates (collectively, “&vest,” “Company,” “us,” our” or “we”) is committed to protecting your privacy. “You/your/user(s)” means you as a user of our Website and Services. This privacy policy applies to all users of our Website and Services and is designed to explain the information we collect and how we use it to provide our Services and give Users a better experience (“Privacy Policy”). Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use. This Privacy Policy is part of, and incorporated into, the Terms of Use.

This Privacy Policy describes the Personal Information (as defined below) we collect about you through the Services, why we collect it, how we use it, and when we share it with third parties. This Privacy Policy also describes the choices you can make about how we collect and use certain of that information. The Personal Information provided by you is not used for any purpose other than as described in this Privacy Policy.

By accessing and using the Website and Services you are agreeing to our collection, storage, use and disclosure of your Personal Information and other information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not provide any Personal Information to us. If you choose not to provide any Personal Information that is necessary for us to provide you with specific products or services, we may not be able to provide those products or services to you.

1. Types of Information We Collect

  1. Personal Information that we collect about you. We collect Personal Information about our users. “Personal Information” is information relating to an individual that can be used to contact or identify you or individuals about whom you enter information as part of your activities on our Services, such as first name, last name, phone number, comments, company name and address, title, and/or e-mail address as well as information that is linked to the forgoing information.
  2. “Aggregated Information”. After stripping out any information that directly identifies you, or directly relates to you, from the Personal Information that we collect about you, we may combine that information with information we collect about other users.
  3. Cookies and Pixel Tags which collect information about users of our Website. We may also use tools such as cookies and pixel tags to gather information as well. “Cookies” are small pieces of information that a website sends to your device while you are viewing the Website. We use both session Cookies (which expire once you close your web browser), persistent Cookies (which stay on your device until you delete them) and third-party Cookies (which are placed by a website from a domain other than ours) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following web browser help file directions. “Pixel Tags” (sometimes called “web beacons” or “clear gifs”) are a snippet of code that collects information about a visitor’s behavior on a website, and then sends the information back to the originating platform to be processed and reported.
  4. Unique Device Identifiers. Like most website providers, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system.
  5. User-Provided Information. We collect information that you provide directly to us when you engage in the following:
    • When you communicate with us via e-mail, telephone, video conference, text message, or other methods
    • When you inquire about, apply for, or initiate employment with us
    • When you are working for us

    We may correlate this information with other Personal Information we have about you. We collect e-mail lists and information related to marketing services. When you use the Website, you may be given the option to subscribe to or to be added to our subscription or e-mail list. Whether or not you select these option(s), your Personal Information may be shared with third parties consistent with this Privacy Policy. You may opt-out or unsubscribe from these e-mail lists.

  6. Hardware; Browser; IP Address. We may collect information from your use of the Website including your hardware model, browser type, operating system, Internet Protocol (IP) address and domain name, through the use of Cookies, web beacons or other technologies. This information may include the following: your browser and mobile device type, operating system and name of your Internet service provider; web pages you visit on the Website; IP address, browser type, profile information, geo-location information; information about your interactions with e-mail messages, such as whether the messages were opened and the links clicked in those e-mails; and standard server log information. If you are using a mobile device, we may also receive your UDID, or another unique identifier, and mobile operating system.
  7. Geolocation. If you access the Website through a desktop or mobile device, we will collect, monitor and/or remotely store geo-location data.
  8. Third-Parties. We may also obtain information from other sources and combine that with information we collect directly. For example:
    • We may also collect information about you from third parties, including but not limited to identity verification services, fraud detection service providers, credit bureaus, and publicly available sources.
    • We use third-party services, such as Google Analytics to track and analyze online behavior of our Users. These services may help inform and optimize our Services. We do this to better understand how you use the Services, with a view to offering improvements for all users, and to tailor our business and marketing activities accordingly.

2. How We Use Your Information

  1. Personal Information. We may use your Personal Information for the following representative purposes:
    • Review and process your requests for information
    • Send communications and administrative e-mails to you
    • Satisfy our contractual obligations to you and provide the materials, goods and/or services that you request
    • Send you promotional/marketing information, newsletters, offers or other information
    • Perform internal operations, processing services, resolve disputes, establish, exercise, and defend legal claims, prevent and identify fraud, verify your identity
    • Personalize and tailor the features, performance and support of the Services
    • Analyze, benchmark and conduct research on user data and interactions with the Services
    • Identify your preferences, so we can notify you of new or additional products, services, contests, and/or promotions that might be of interest to you
    • Improve our services, content, customer service, and overall user experience by aggregating and analyzing user data
    • Analyze the use of our products and services and information about users of the Services to enhance our marketing efforts
    • Communicate with you by e-mail, video conferencing, telephone, text message, app notifications, or other means about our company, our products, or other information that we believe may be of interest to you
    • Provide others with your Personal Information for the limited purposes described in this privacy policy
    • Send you notices of a transactional, administrative or relationship nature, or as required by law
  2. Aggregated Information. We may use Aggregated Information for the following representative purposes:
    • Perform internal operations on the Services
    • Improve the Service, and customize the user experience
    • Aggregate the information collected via Cookies and Pixels to use in statistical analysis to help us track trends and analyze patterns

3. Lawful Processing; Legitimate Interests. Our processing of your Personal Information for the purposes set out in this Privacy Policy is necessary for one or more of the following:

  • Performing a contract with you, or to take steps at your request prior to contracting with you
  • Protecting your vital interests or the interests of another person
  • Complying with our legal obligations
  • Pursuing our legitimate interests, including without limitation:
    • Providing, improving and customizing our Services;
    • Administration of our operations;
    • Maintaining our accreditation status and complying with all reporting obligations related thereto;
    • Maintaining an ongoing relationship with healthcare providers, donors and prospective donors, and helping to connect them with others;
    • Understanding how our Services are being used;
    • Exploring ways to develop and grow our business;
    • Ensuring the safety and security of our employees and others;
    • Cybersecurity;
    • Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
    • Meeting our obligations and enforcing our legal rights

4. How We Share and Disclose Personal Information

  1. If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to use the Services or provide your Personal Information at any time. If you choose not to provide any Personal Information that is necessary for us to accept you into our programs or to provide you with specific products or services, we may not be able to provide those programs, products or services to you.
  2. We may disclose your Personal Information to outside individuals and/or companies that help us bring you the services and products we offer and to create, operate, and maintain our Services. For example, we may work with third-parties to: (a) manage a database of customer information; (b) assist us in distributing e-mails; (c) assist us with direct marketing and data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service; and (g) provide other services designed to assist us in developing and running our Services and maximizing our business potential. We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us.
  3. We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

5. Use of Aggregated Information.

  1. We use Aggregated Information to maintain and administer the Website and Services, analyze trends, gather demographic information and comply with applicable law. We may share Aggregated Information with third-parties. We may share this information with others without express notice to you or consent from you, and we may, subject to applicable laws, exploit, use and disclose Aggregated Information without limitation of any kind. We authorize certain service providers to utilize Aggregated Information for their business purposes and in accordance with their privacy policies, such as to report on usage or industry trends to their customer base.
  2. The Website may use Cookies. Cookies help us remember you when you return to the Website. Cookies also hold information to personalize and enhance your experience and to gather Website statistical data, such as which pages are visited, the Internet provider’s domain name and the addresses of the sites you visited immediately before coming to and immediately after leaving the Website. The information in the cookies lets us trace your “clickstream” activity (i.e., the paths taken by users of the Website as they move from page to page) to enable us to better serve you by revealing which portions of the Website are the most popular. We may also allow our affiliate and service providers and advertisers to serve cookies from the Website to allow them to assist us in various activities such as doing analysis and research on the effectiveness of the Website, its content and advertising. Some third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offer a single location to opt out of ad targeting from member companies. For more information, see: www.networkadvertising.org.
  3. We may also use Pixel Tags, which help us analyze users’ online behavior and measure the effectiveness of the Website and our advertising and marketing. Pixel Tags or Clear gif files are tiny graphics with a unique label that work in a similar way to cookies and are used to monitor the user’s online activities. In contrast to cookies that are saved on a user’s computer hard disk, clear gif files are embedded invisibly in websites and are about as big as the full stop at the end of this sentence. Where appropriate, we may combine the information collected by such Pixel Tags with the Personal Information of our customers. We may also use other analytical tools to evaluate site performance through the use of aggregated data, which contain no Personal Information. We work with service providers that help us track, collect, and analyze this information.
  4. Cookies, Pixel Tags, and/or other analytical tools that we may use on the Website may collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with the Website. This information may include your computer’s Internet protocol (IP) address, your browser type, your operating system, date and time information, and other technical information about your computer. We may also track certain information about the identity of the Website you visited immediately before coming to the Website. Cookies, pixel tags, and/or other analytical tools in our e-mails may also be used to track your interactions with those messages, such as when you receive, open, or click a link in an e-mail message from us. We may also work with businesses that use tracking technologies to deliver advertisements on our behalf across the Internet. These companies may collect information about your visits to the Website and your interaction with our advertising and other communications, but no Personal Information is shared with them.
  5. We may combine the information collected through Cookies, Pixel Tags and other analytical tools with other information we may have collected from you. This information may be used to improve the Website, to personalize your online experience, to help us deliver information to you, to determine the effectiveness of advertising, and for other internal business purposes. We may use and share aggregated and anonymous information to conduct market research and analysis for ourselves and/or for our business partners. For example, we may freely share such information with third parties who may use such data for their own marketing, advertising, research, or other business purposes. We may also freely share such information with our service providers in order for them to perform services to or for us.

6. Data Retention.

  1. We will retain your Personal Information for as long as is necessary for the purposes set out in this Privacy Policy unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations.
  2. Where we are processing Personal Information based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.
  3. Where we are processing Personal Information as set out in this policy, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Information erased (see Section 7, Deleting, Changing & Updating Your Personal Information).
  4. Where we are processing Personal Information based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.

7. Opting-Out

  1. Unsubscribe. You may opt out of: (a) receiving e-mail communications such as e-mail newsletters and promotional e-mails by following the instructions provided at the bottom of each e-mail, clicking the “unsubscribe” button at the bottom of e-mails we sent you; and/or (b) receiving promotional e-mail communications and newsletters by e-mailing us at hello@andvest.co and including the word “UNSUBSCRIBE” in the subject text. Opting out of receiving Website communications will not affect your receipt of service-related, and administrative communications, such as payment confirmations, delivery status updates, updates to our Terms of Use and this Privacy Policy as we must be able to communicate with you regarding your purchases. If you do not receive a response from us to any e-mails you send to us within ten (10) business days, please send us another e-mail as your original e-mail may not have been received.
  2. Google Analytics and Apple. Our products and services may use Google Analytics Advertising Features and its associated tracking technologies to help display and retarget our ads you see on other sites, and to help us manage and optimize our online advertising efforts. To opt out of Google Analytics Advertising Features, visit Google’s Ad Settings page, currently located at https://adssettings.google.com/authenticated. Website users can also access the Google Analytics Opt Out Browser Add-on, currently located at https://tools.google.com/dlpage/gaoptout. We may also work with Facebook and Apple to provide analytics and advertising retargeting in connection with our Website, including our mobile applications.For Apple’s privacy policy, click here http://www.apple.com/privacy/privacy-policy/ and learn how to control what you share and opt-out of sharing here https://www.apple.com/privacy/control/.
  3. Cookies. You can opt out of accepting Cookies or disable them from your browser. The “Help” function on most browsers contains information on how you can set your browser to notify you before accepting Cookies or can disable them entirely. If you opt out of Cookies, you will not be able to take advantage of various features of the Website that are available to other users. For example, we may use Cookies to recognize you by name when you return to this Website so you don’t have to login again and provide your password each time.

8. BASIS FOR CONTINUED USE OF YOUR PERSONAL INFORMATION.

Please note that, in certain cases, we may continue to process your Personal Information after you have withdrawn consent and requested that we delete your Personal Information, if we have a legal basis to do so. For example, we may retain certain data if we need to do so to comply with an independent legal obligation, if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure. Furthermore, if we have already disclosed your Personal Information to third-parties pursuant to the terms of this Privacy Policy, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures.

9. Notice to Californian Users Regarding Your Privacy Rights

  1. Shine the Light. Pursuant to California Civil Code Section 1798.83, also known as the “Shine The Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third-parties. We do not share Personal Information with third-parties for those parties’ direct marketing. To request the above information, California residents can e-mail us at contact us via e-mail at hello@andvest.co or write to us at Attn: Privacy Office, 109 Old Branchville Road, Ridgefield CT 06870. Please note that, under California law, a business is only required to respond to such a request twice in any calendar year.
  2. Do Not Track. Some web browsers may let you enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a “do not track” feature enabled may still accept cookies. There is currently no industry standard for how companies should respond to “do not track” signals, although one may develop in the future. We do not respond to “do not track” requests or signals at this time.

10. Children

This Website is not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Website is targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13. If we later obtain actual knowledge that a User is under 13 years of age we will take steps to remove that User’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at contact us via e-mail at hello@andvest.co or write to us at Attn: Privacy Office, 109 Old Branchville Road, Ridgefield CT 06870 so that we may delete and remove such information from our system.

11. Security

We strive to keep your Personal Information private and safe. Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Website, any transmission of Personal Information by you is at your own risk. We cannot guarantee that such information will not be intercepted by third-parties and we shall not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for circumvention of any privacy settings or security measures contained on the Website.

12. Third-Party Websites

While visiting the Website, you may link to websites operated by third parties or you may have come to the Website using a link found in another website. We do not make any representations or warranties about any third-party website, we have no control over them or the information, services, products they provide or the manner or methods they employ to collect, store, access, or otherwise use your Personal Information. If you provide Personal Information at one of those websites, you are subject to the privacy policy of the operator of that website, not our Privacy Policy. Please make sure you understand any other website’s privacy policy before providing Personal Information.

13. Changes to Our Privacy Policy

We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted. However, we will not use your Personal Information in a way that is adverse and materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out. The “Last Modified” date indicates if and as of when changes have been made to this Privacy Policy. Your continued use of the Website after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended.

14. Contact Us

If you have any questions regarding our Privacy Policy, or if you wish to issue a request to exercise your rights where applicable by law, you can contact us via e-mail at hello@andvest.co or write to us at Attn: Privacy Office, 109 Old Branchville Road, Ridgefield CT 06870