Last updated: December 1, 2024

Privacy Policy

Note: This is a prototype/demo application. This Privacy Policy is structurally realistic but is placeholder text for demonstration purposes only.

1. Information We Collect

We collect information you provide directly to us, such as when you create an account, complete investor onboarding, make an investment, or contact us for support. This includes: (a) Identity information (name, date of birth, SSN last 4 for identity verification); (b) Contact information (email, phone, address); (c) Financial information (income, net worth, bank account for KYC/AML compliance); (d) Investment information (amounts invested, campaigns backed, securities held); (e) Communications you send us.

2. How We Use Your Information

We use the information we collect to: (a) Operate the Platform and process your investments; (b) Comply with Regulation CF and other applicable laws, including KYC/AML requirements; (c) File required SEC reports (including disclosing investor information in Form C filings as required by law); (d) Send you administrative emails, campaign updates, and investor notices; (e) Detect and prevent fraud; (f) Improve our Platform. We do not sell your personal information to third parties.

3. Required Disclosures

As a registered funding portal, Seedling is required by law to disclose certain investor information in SEC filings. Specifically, aggregate investor data and, in some cases, individual investor identities may be disclosed in Form C filings made by issuers. By investing on our Platform, you acknowledge that your participation in offerings may be publicly disclosed.

4. Data Sharing

We share your information with: (a) Escrow agents and payment processors (to process your investments); (b) Identity verification services (for KYC/AML compliance); (c) Issuers (to facilitate the issuance of securities to you); (d) Legal and regulatory authorities (as required by law); (e) Our service providers (under confidentiality agreements). We do not share your information for third-party advertising or marketing purposes.

5. Data Security

We implement industry-standard security measures to protect your information, including encryption at rest and in transit, multi-factor authentication, and regular security audits. However, no system is completely secure, and we cannot guarantee the absolute security of your information.

6. Data Retention

We retain your information for as long as your account is active and as required by applicable securities law (which may require us to retain records for up to 7 years). You may request deletion of your account, but we may be required to retain certain records for legal and regulatory compliance.

7. Your Rights

You have the right to: access the personal information we hold about you; correct inaccurate information; request deletion of your account (subject to legal retention requirements); opt out of marketing communications. To exercise these rights, contact privacy@seedling.fun.

8. Contact

If you have questions about this Privacy Policy, contact our Privacy Officer at privacy@seedling.fun or Seedling, Inc., 340 Pine Street, Suite 800, San Francisco, CA 94104.