February 11, 2013
LOYAL3 offers and supports web & social media sites (“sites”) that allow companies (each a “company”) to connect
customers to enroll in a Social Stock Plan™,
other financial products, including Social IPOs (an “IPO”). LOYAL3’s platform allows customers to buy stock directly
through a Plan,
either purchasing stock that LOYAL3 purchases in the stock market or stock provided directly by the company. Through
LOYAL3 platform, you may also effect transactions in certain equity securities of companies traded on a U.S. stock
market that are
not part of a Plan or IPO. LOYAL3 makes these stocks available based on its own criteria — such as social
and other indicia of broad appeal to consumers as selected by LOYAL3 — and the fact that LOYAL3 is making
these stocks available
has no relation to the value of such stocks. We are committed to protecting the personal and financial information
of our customers,
including persons inquiring about potential services (“customers” or “you”). In the course of providing financial
services to you, we need to collect (from you and other sources) and maintain certain nonpublic personal
information. This privacy
policy provides information about what nonpublic personal information we collect, what we do with it, and how we
We do not disclose nonpublic personal information about our customers to non-affiliated third parties except as
specifically described below.
Please read the following information about how we handle your information.
as referenced below, by never sharing your LOYAL3 account information or your password.
Who is LOYAL3?
"us," and "our" throughout this statement.
We collect your IP address, browser type, and operating system on each visit to every page on our sites on our
This information is used only for internal statistic tracking purposes and is
never shared with other entities outside LOYAL3,
including affiliates as described below, unless required by law or as otherwise disclosed within this policy. Your
other information are not collected unless you specifically provide it.
Email and other electronic delivery
We do communicate using electronic channels, such as email and email notifications about information that our
customers may access by logging
into their accounts. LOYAL3 also delivers email on behalf of companies to their investors including investor-related
information and consumer information.
What types of nonpublic personal information does LOYAL3 collect?
By opening a LOYAL3 account, you provide personal information, including your name, address, email address, date of
birth, and Social Security number,
as well as checking account and/or credit/debit card information. We will also obtain information regarding your
transactions and activities
in your account. In addition to information provided by you, we may also obtain personal information from the
companies that make stock offers
to you using our technology and services (the “Service”), as well as from identity verification services and
third-party information providers.
How we share your information
We share your information to provide the Service related to your participation in the LOYAL3 platform, to fulfill
or permitted by law.
We will never sell your personally identifiable information. The companies whose stock you purchase are not
responsible for the collection
or security of the information we obtain from you by means of your establishing a LOYAL3 account.
Information sharing with companies
We provide your name, contact information, and demographic data to a company in whose Plan or IPO you have
enrolled as a customer-owner,
or name and contact information to companies whose other stock you purchase through LOYAL3, unless you elect not to
allow that type of sharing.
That company will use your information in accordance with its own independent privacy policies. You may make this
decision when you enroll
and establish your LOYAL3 account, as well as change your choice on “My LOYAL3 Account.” In addition, LOYAL3
provides analytics for companies
about their Plan participants. Such analytics are provided by LOYAL3 on an aggregate basis only. If you opt out of
with the companies, we will not share your identity with your companies to obtain information from them to perform
In any case, LOYAL3 will not provide access to any of your personal information to any of the companies other than
those in which you are a shareholder.
We also will not share the following information, including with any of the companies: password, occupation,
employer, employer’s address,
checking account information, and Social Security number. Social Stock Plans by certain companies are contingent on
both LOYAL3 and the company
knowing the identity of the customer and certain information about the customer. This may be the case with a Plan in
which a company,
for example, (a) makes offers involving the granting of shares or a discount for consumer commitments or purchases,
(b) offers consumer
discounts based on the purchase of Plan shares, (c) grants shares or discounts to certain customers or other
persons, or (d) offers shares
for customer affinity points. In such cases, by enrolling in the offer, you permit the company and LOYAL3 to share
to effect the intended transactions.
Promotional messages delivered by LOYAL3
LOYAL3 Securities may deliver promotional messages from the companies you own as well as from LOYAL3. If you choose
not to receive such
messages, you may make that choice on any message you receive and you will then receive only messages that are
required to provide services
you requested, purely operational communications, or as required or permitted by law. You may not opt out of these
LOYAL3 provides a social media platform to easily facilitate your sharing of your actions or experience through
your chosen social
media provider, such as Facebook or Twitter. LOYAL3 is dedicated to providing you choice and control in what you
these platforms. You are responsible for understanding the features and your settings on Facebook, Twitter, and
media providers. This may necessitate your investigation into the privacy policies and practices of those providers,
strongly encourage you to undertake before using those features on LOYAL3.
Links to other sites
Our sites include links to other websites whose privacy practices may differ from those of LOYAL3’s. If you submit
information to any of those sites, your information is governed by their privacy policies. We encourage you to
read the privacy statement of any website you visit.
Chat, email, and telephone
We use an online chat feature, email, and telephone to assist you with technical and administrative questions you
We do not provide financial advice of any kind.
How do we track activity and site usage?
When you visit the sites, we may collect technical and navigational information, such as computer browser type, IP
pages visited, and average length of time spent on our sites. We may also record the time of actions taken on the
sites for regulatory or other control purposes.
- Allow you to avoid having to re-enter information and to aid in navigation between pages of our sites.
- Help us recognize you as a unique user when you return to our sites.
- Remember what kinds of information you have shown interest in while on our sites.
- Collect and compile anonymous, aggregated information for statistical and evaluation purposes to help us
understand how users use our site and to help us improve its structure.
No personal information is stored in our cookies. You may be able to disable cookies by changing your browser
but our sites’ functionality and your experience may be diminished as a result. For more information about cookies
to disable them please visit http://www.allaboutcookies.org.
Web beacons are images embedded in a web page or email for the purpose of measuring and analyzing site usage and
LOYAL3, or third-party service providers acting on our behalf, may use web beacons and/or cookies to help us to
site usage and improve the Service. We do not share any personally identifiable information about you with these
service providers, and they do not collect such information on our behalf.
We are committed to your security.
At LOYAL3, we value our relationship with our customers and place the highest importance on respecting and
protecting your private data.
We want you to feel comfortable and confident when using our products and services and with entrusting your personal
information with us. With these principles as our guide, we continually enhance our systems and processes as online
Because no single solution can ensure online security, we employ a layered security approach with industry-leading
When you enter sensitive information (such as a credit card number) on the LOYAL3 platform, we encrypt the
transmission of that
information using secure socket layer technology (“SSL”).
Your communications with us are secure.
Communications between your computer and LOYAL3 are encrypted using SSL technology. SSL enables “client/server”
communicate in a way that is designed to prevent eavesdropping, tampering, and message forgery.
To support this technology, you need a recent version of an SSL-capable, 128-bit browser, such as Internet Explorer
7 & 8,
Firefox, or Safari. These browsers will activate SSL automatically whenever you log onto our sites. To ensure that
encryption is protecting your private communications, look for a small picture of a padlock on the browser frame.
Another indicator is the URL prefix “https.”
Ways you can help keep your information secure.
When you log onto a LOYAL3 site, you are authenticated by your user name and password. You will be asked for other
identifying information for any contact with LOYAL3 when you are not logged onto the site, but we will never ask for
We strongly recommend that you change your password frequently. Your password must follow the password requirements
required when you enroll or update your password. You are responsible for maintaining the security of your password
must not provide it to any third party. If you believe that it has been stolen or made known to others, you must
update your password on our site. We are not responsible if someone else accesses your LOYAL3 account through
How you can access and update your nonpublic personal information
You can access or update certain nonpublic personal information that we collect about you by logging into your
account site using your user name and password. From the home page, click the “Log In” tab at the top of
any page on LOYAL3.com and select the information you want to change. You can directly correct inaccurate personal
We will retain your information for as long as your account is open or as needed to provide you with services (such
for year-end tax reporting after your account is closed). In addition, we will retain and use your information as
necessary to comply with our legal obligations, resolve disputes, and enforce our agreements (including, for
maintaining most information for at least six years).
Please contact us with any questions.
button on LOYAL3.com or when logged into your account or by mail to LOYAL3 Support Services, Box 26027, San
Francisco, CA 94126.
State Laws: If your address is in Vermont, we will not share information we collect about you
with non-affiliated entities, except as permitted by Vermont law, such as to service your account and according to
©2013 LOYAL3 Securities, Inc.