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LOYAL3 Privacy Policy & Security Practices

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December 2014

LOYAL3 offers and supports web & social media sites ("sites") allowing investors to enroll in a Social Stock™ Plan™ offering by a company for its consumers and other persons (a "Plan"; formerly known as a "Customer Stock Ownership Plan" or "CSOP"™) as well as other financial products, including Social IPOs (an "IPO"). Through the sites, 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 media prominence 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. Any company whose stock you can purchase on a site, whether through a Plan, an IPO, or as a stock made available is called a “company” in this privacy policy & security practices.

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 products and 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 protect it.


Privacy Policy

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. While our privacy policy guides our actions, it also imposes certain requirements on you to protect your information, as referenced below, by never sharing your LOYAL3 account information or your password.

Who is LOYAL3?

This privacy policy covers LOYAL3 Securities, Inc. (Member FINRA/SIPC), which is referred to as "LOYAL3," "we," "us," and "our" throughout this statement.

Websites

We collect your IP address, browser type, and operating system on each visit to every page on our sites. 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 name and 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, as well as text messages. LOYAL3 also delivers email on behalf of companies to their investors including investor-related information, some of which is required by regulation, 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, you occupation and employer, 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 on the sites, to fulfill your requests for certain offers, rewards, products, and services, and as otherwise described in this privacy policy or required 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 or whose stock you have purchased on the sites, 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 when logged into your account. In addition, LOYAL3 provides analytics for companies about investors in their stock. Such analytics are provided by LOYAL3 on an aggregate basis only. If you opt out of information sharing with the companies, we will not share your identity with the companies to obtain information from them to perform the analytics. 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 with any of the companies: password, occupation, employer (unless the company is your 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 consumers, employees or other persons, or (d) offers shares for consumer affinity points. In such cases, by enrolling in the offer, you permit the company and LOYAL3 to share information required 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 as well as messages from LOYAL3, 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 non-promotional communications.

Social Media

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 share through these platforms. You are responsible for understanding the features and your settings on Facebook, Twitter, and other social media providers. This may necessitate your investigation into the privacy policies and practices of those providers, which we 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. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully 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 may have. 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 address, 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.

This is accomplished through the use of "cookies." We use cookies to:

  • 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 settings, but our sites’ functionality and your experience may be diminished as a result. For more information about cookies and how to disable them please visit http://www.allaboutcookies.org. (For the mobile application, cookies are required to support a session and are not removable but still do not store personal information.)

Web beacons are images embedded in a web page or email for the purpose of measuring and analyzing site usage and activity. LOYAL3, or third-party service providers acting on our behalf, may use web beacons and/or cookies to help us to analyze site usage and improve the Service. We do not share any personally identifiable information about you with these third-party service providers, and they do not collect such information on our behalf. LOYAL3 web and mobile applications may collect usage, stability, and performance data for statistical and evaluation purposes

Additional Mobile Application Elements

Upon logout from the application, personal information is cleared from your device with the exception of your email address. With your permission, we may store login information, including email and password (subject to sophisticated encryption) for easier app re-entry, and may collect specific user data for purposes of identifying with you any stability or performance issues.


Security Practices

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 and financial information with us. With these principles as our guide, we continually enhance our systems and processes as online services evolve. Because no single solution can ensure online security, we employ a layered security approach with industry-leading solutions.

When you enter sensitive information (such as a checking account 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" applications to 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 (we support the most popular browsers, which may change from time to time). These browsers will activate SSL automatically whenever you log onto our sites. To ensure that SSL 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 your password by email, chat or on the phone.

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 and must not provide it to any third party. If you believe that it has been stolen or made known to others, you must promptly update your password on our site. We are not responsible if someone else accesses your LOYAL3 account through information obtained from you or through your violation of this privacy policy and your account agreement with us.

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 information.

Data retention

We will retain your information for as long as your account is open or as needed to provide you with services (such as 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 example, maintaining most information for at least six years).


Changes to the privacy policy.

LOYAL3 reserves the right to revise this privacy policy at any time and will notify you of any revised policy.

Please contact us with any questions.

Questions regarding this Privacy Policy and Security should be directed to LOYAL3 by email to support@loyal3.com, using the chat function on loyal3.com or by mail to:

LOYAL3 Support Services
Box 26027
San Francisco, CA 94126

State Law: 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 your consent.

Important Notice for California Residents

©2014 LOYAL3 Securities, Inc.