Capital Pad’s Privacy Notice

Last Updated: June 18, 2024

This privacy notice (“Privacy Notice”) is intended to provide you with specific details about how CapitalPad Manager LLC, which owns and operates capitalpad.com (“Capital Pad,” “we,” and “us”), collects and processes your personal and personally identifiable information through your use of its website and its associated services (collectively, the “Services”).

THIS PRIVACY NOTICE

Why we Have this Privacy Notice and What it Covers

You understand and agree that Capital Pad may store and process your personal information on computers located outside of your jurisdiction, including, but not limited to, in the United States. By using the Services, you agree to the collection and processing of your personal or personally identifiable information outside of your jurisdiction.

Before using the Services or providing information to us, please carefully review this Privacy Notice. By using or accessing the Services, you agree that we may collect and use your personal and personally identifiable information in accordance with this Privacy Notice, as revised from time to time. Capital Pad may modify, amend, replace, or suspend this Privacy Notice at any time. If you have any questions or suggestions regarding our Privacy Notice, or if your personal information is not accurate or complete, please contact us at:

Capital Pad

ATTN: Compliance Officer

2028 East Ben White Boulevard
#240-8228
Austin, TX 78741

Or via email at privacy@capitalpad.com.

By providing Capital Pad with your personal or personally identifiable data and using the Services, you warrant that you are over the age of eighteen (18) or otherwise above the age of majority within your jurisdiction. If you are younger than eighteen (18) or the age of majority within your jurisdiction, please do not use the Capital Pad Services and please do not provide personal information to us.

Our Services may include links to websites or may include the use of analytics tools that are owned, operated, and maintained by third parties. Capital Pad does not exercise control over the privacy practices such third-party websites or analytics tools, and you are encouraged to review the privacy practices of all such third-party websites or analytics tools disclosed within this Privacy Notice.

OUR DATA PRACTICES

What Data we Collect, How and Why we Collect it, and How we Use and Secure it

What information do we collect and how do we use it? 

When you use the Services, we may collect personal or personally identifiable information from you (“PII”). PII may include any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include anonymized data.

We may collect and process the following categories of PII about you:

• Communication Data. Communication data includes any communication that you may send to us through the Services, email, or social media. We process this data to communicate with you by email or other means, to provide you with customer support, to record logs of our communication, and to store information to respond to legal claims. Capital Pad’s lawful ground for collecting and processing this PII is to respond to communications sent by you to us, to keep records of our communication, and to pursue or defend against legal claims.

• User Data. User data includes data about how you use the Services and any data that you post to or authorize through the Services, such as your name, address, country, phone number, and email address. This includes data stored in persistent cookies when you login to the Services and analytics data that is collected when you use the Services. We collect and process this data to operate the Services, to authenticate you as a user of the Services, to ensure that timely and relevant content is provided to you, to secure the Services, to ensure that the Services operates in a fast and efficient manner, and to maintain backups of the Services. Capital Pad’s lawful ground for processing this user data is its legitimate business interests in administering and offering the Services and to fulfill your orders made through the Services.

• Technical Data. Technical data includes data about your use of the Services, such as your IP address, your login data, your phone number, your mobile device model, your operating system, your geolocation, and your time zone. We may collect this data from your use of the Services and from advertising IDs. Capital Pad processes this data to analyze your use of the Services, to route Services traffic, to administer and secure the Services, to provide location-relevant content, and to troubleshoot problems with the Services. Capital Pad’s lawful ground for collecting and processing this technical data is its legitimate interests in administering and offering the Services and to grow its business and marketing strategy.

• Marketing Data. Marketing data includes data about your preferences in receiving and interacting with Capital Pad’s advertisements or content on the Services or on third party websites or applications. We may collect this data from your use of the Services and from third party advertising IDs created through advertising programs, such as Google Advertising IDs and Facebook Advertising IDs. Capital Pad does not connect advertising identifiers to persistent device identifiers, such as MAC addresses or mobile device IDs. Capital Pad’s lawful ground for collecting and processing this marketing data is its legitimate interests in administering and offering the Services and to grow its business and marketing strategy by providing advertisements, including remarketing advertisements, to you.

Capital Pad will only use your PII for the purpose for which it was collected. If Capital Pad needs to use your PII for an unrelated, new purpose, Capital Pad will provide you with notice of this new use and will explain the lawful ground for such processing. Capital Pad may process your PII without your knowledge or consent where required or permitted by law.

How do we collect this information?

We collect PII from you through a variety of different means:

• Direct Collection. We may collect PII from you when you use our Investment Services, register an Investor Account, contact us through the Website, via live chat, social media, or otherwise, respond to a survey, participate in a contest, or when you opt-in to receive marketing emails, or mailings from us.

• Third Party Tracking Tools. We use third-party tracking tools, such as pixels, web beacons, and cookies, to automatically collect PII from you when you open, view, or click pages or links, emails, or advertisements. We disclose these third-party tracking tools below in this Privacy Notice in our disclosure of PII that we collect from third parties.

• Business Partners and Service Providers. We may, from time to time, obtain PII from our business partners or service providers. When we obtain PII from our business partners and service providers, we ensure that all such business partners and service providers have obtained consent from you to transfer all such PII to us for its intended uses.

• Social Media Networks and Other Platforms. We may obtain PII from you when you interact with our social media accounts or content posted on other third-party platforms, such as Facebook, X, or YouTube. For more information on how your PII may be disclosed by a particular social media network or platform, you are encouraged to review the privacy notices and policies of those platforms.

• Analytics Providers. We may also obtain PII from you through our use of third-party analytics providers, such as Clicky. See below for a complete list of analytics services we partner with. We may create user profiles based on PII obtained through our use of PII from third-party analytics providers to better understand your wants and needs as a customer.

What information do we collect from third parties and how do we use it?

Capital Pad may collect data about you through cookies and other technologies. This helps Capital Pad understand how you use the Services and to understand any patterns that may be associated with your use of the Services. This aids Capital Pad in developing or improving its Services and marketing communications in response to your needs or wants.

Capital Pad may use session or persistent cookies. Session cookies are only stored on your computer or mobile device during your use of the Services and are automatically deleted when you close your web browser. Session cookies may be used to direct internet traffic to a server that is closer to you or to allow us to identify you as you move between pages of the Services. Persistent cookies are stored as a file on your computer or mobile device that remains on your computer or mobile device even after you close your web browser. Persistent cookies can be read by the Services that created the cookie when you revisit it again. Capital Pad may use persistent cookies to authenticate you when you return to the Services so that you do not have to login again or when it utilizes Google Analytics or other analytics providers, which is intended to track the origin and behavior of traffic to the Services. Capital Pad may use the following analytics providers, and you are directed to review their cookie policies:

ConvertKit: https://convertkit.com/privacy

Clicky: https://clicky.com/terms/privacy

Google Analytics: https://policies.google.com/technologies/partner-sites

Elementor: https://elementor.com/about/privacy/

RankMath: https://rankmath.com/privacy-policy/

Resend: https://resend.com/legal/privacy-policy

WordFence: https://www.wordfence.com/privacy-policy/

Capital Pad may also receive data from third parties including analytics providers or advertising networks such as Google, Facebook, TikTok, or Apple. These third parties may be based outside of your jurisdiction.

How do we use your information for marketing communications? 

As stated above, Capital Pad’s lawful ground for sending you marketing communications is either consent or its legitimate business interests, such as to grow its business by advertising products and services to you. Capital Pad may send you marketing communications if you have asked for information concerning its goods or services or if you have agreed to, and have not opted out from, receiving marketing communications. You may ask Capital Pad to stop sending you marketing messages at any time by following the opt-out link in any marketing message sent to you. If you opt out of receiving marketing communications, your opt-out does not extend to PII provided for other purposes.

When do we disclose your information?

Capital Pad may share your PII with the following parties:

• Service providers that provide Capital Pad with information technology, software as a service, cloud storage, or other administrative services;
• Capital Pad’s accountants, auditors, insurers, or attorneys;
• Law enforcement agencies upon the receipt of a subpoena or court order or where necessary to protect Capital Pad’s personnel or property; and
• Government bodies that require Capital Pad to report its processing activities.

Capital Pad may also transfer PII to third parties when it sells, transfers, or merges any part of its business or assets.

How do we protect your information? 

Capital Pad has developed, implemented, and maintains a comprehensive information security program that helps us (1) identify reasonably foreseeable risks to the security, confidentiality and integrity of customer information; (2) design and implement information safeguards; (3) test and monitor those safeguards; and (4) adjust those safeguards as needed. Capital Pad has put into place data security measures to protect your PII.

We implement a variety of security measures to maintain the safety of your personal information, including when you invest. However, no security measures are impenetrable and there are always security risks. Capital Pad will notify you and any regulatory body of any breach of your PII or Capital Pad security measures if it is legally required to do so. As part of these security measures, Capital Pad allows access to your PII only by employees and service providers who have a need to know or access your PII on Capital Pad’s instructions.

Do we use cookies? 

Yes, as stated above, we may use persistent and session cookies. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information. We may use cookies to help us remember, understand, and save your preferences for future visits, and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

For how long do we retain your data?

We will only retain your PII for so long as necessary to fulfill the purposes for which it is collected under this Privacy Notice or for the purposes of satisfying any legal, accounting, or reporting requirements. With respect to location data, technical data, usage and interaction data, and marketing data, we may retain this data for so long as it is relevant to the uses disclosed in this Privacy Notice. We may retain account data, public data, and communications data for so long as you maintain a user account with Capital Pad, and we may retain this data for longer periods where there is a need to retain this data to comply with Capital Pad’s legal obligations, such as the preservation of electronic evidence or compliance with a preservation order.

Third Party Links

Capital Pad’s Services may include links to third-party websites and applications. By clicking on third party links, you may allow third parties to collect or share data about you. Capital Pad does not control these third-party links and you are advised to review their respective privacy policies.

Childrens’ Online Privacy Protection Act Compliance

We comply with the requirements of COPPA (Childrens’ Online Privacy Protection Act). We do not knowingly collect any information from anyone under 13 years of age, and our Services are marketed to and are only accessible by individuals 18 years of age or older. If you believe that we have collected PII from someone under the age of 13, you are directed to notify us immediately at privacy@capitalpad.com.

Responding to Do Not Track Signals

You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI Services and DAA Services. Our Services are not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what “do not track” means in this context, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set.

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/.

YOUR PRIVACY CHOICES

Right of Access, Rectification, Correction, Erasure, Transfer, and Withdrawal

Under the law, you may have a right to request access to your PII for rectification, correction, erasure, transfer, or restriction, or to object to its processing or withdraw your consent. If you wish to exercise any of these rights, please contact Capital Pad’s Data Protection Officer as disclosed in this Privacy Notice.

You do not need to pay a fee to access your PII or to exercise your rights. However, Capital Pad may charge a reasonable fee if your request is unreasonable or excessive.

To confirm your request, Capital Pad may need to request specific information from you as a security measure to ensure that PII is not disclosed to an unauthorized third party. Capital Pad will attempt to respond to all legitimate requests within thirty (30) days.

Rights of European Citizens

Capital Pad adheres to the EU-U.S. Data Privacy Framework (“DPF”) Principles, including the DPF’s Supplemental Principles, and complies with the Principles in handling all data from EU-citizens. Capital Pad is subject to the enforcement powers of the United States Federal Trade Commission (“FTC”) in relation to its handling of user data. Capital Pad is not certified under the DPF by the FTC or any other regulatory body but adheres to the Principles in handling all data from EU-citizens to the best of its abilities.

If you are a European citizen, you are entitled to certain rights regarding the protection of your Personally Identifiable Information and Personal Data, which are subject to limitations set forth in the EU GDPR and its applicable case law. These rights are:

• The right to access and correct the information that Capital Pad processes about you;
• The right to transfer all or a part of the information collected about you to another data controller, where it is technically feasible;
• The right to the erasure of data concerning you, subject to Capital Pad’s rights of retention under the law;
• The right to object to the processing of Personally Identifiable Information and Personal Data where you dispute the accuracy of the data, the processing is not lawful, Capital Pad no longer needs the information for the purposes of processing, or you have raised an objection for personal reasons;
• The right to revoke your consent to data processing;
• The right to object to the processing of your Personally Identifiable Information and Personal Data for marketing purposes;
• The right to object to the processing of Personally Identifiable Information and Personal Data for direct marketing or for personal reasons that arise from your particular situation; and
• The right to file a complaint with a data protection authority.

To exercise these rights, you may either opt out of receiving communications from Capital Pad by unsubscribing to its e-mails or by contacting us at privacy@capitalpad.com. You do not need to pay a fee to exercise these rights, however, Capital Pad reserves the right to charge a reasonable fee if your request is unreasonable or excessive. To confirm your request, we may need to request specific information from you as a security measure to ensure that personal data is not disclosed to an unauthorized third party. We will attempt to respond to all legitimate requests within thirty (30) days.

For further information regarding your privacy rights as a citizen of the EU, please visit the U.S. Department of Commerce’s Services at https://www.commerce.gov/ and the DPF overview webpage at https://www.dataprivacyframework.gov/s/program-overview.

California Privacy Rights

The following rules apply solely to visitors, users, and others who are residents of the State of California. California residents have the right to be notified which categories of PII are being collected and the purposes for which the PII is being used. In particular, we collected the following categories of PII (A, B, D, E, F, and G) as defined in the California Consumer Privacy Act within the last twelve months. Our uses of this PII are detailed above in this Privacy Notice:

We obtain the categories of PII marked “YES” in the above table (Table T.1) directly from California residents when they complete forms through our Services or provide it to us as a part of a transaction or inquiry concerning our Services. We also obtain these categories of PII indirectly from California residents while observing their actions on our Services and from third parties or service providers that they have authorized to receive and share PII.

California residents have a right to request that we disclose what PII we collect from you and whether, and how, we disclose or sell that PII. California residents may also request that we delete any personal information collected or maintained by us from you.

California residents may also have the right to opt out of the sale of their personal information by contacting us or, where available, by clicking a link or icon associated with an advertisement. Specifically, this link or icon may state “Do Not Sell My Personal Information.” By selecting this link or icon, you “Opt Out,” which means that you have opted out of the sale of your personal information as set forth in the California Consumer Privacy Act. However, even though you may have opted out, you may still see interest-based advertisements. To learn more about interest-based advertising across websites and additional opt-out choices, you can visit http://optout.aboutads.info. If you opt-out of the sale of your personal information but do not opt out of interest-based advertising more generally, you may still receive ads tailored to your interests based on PII that was not sold by us, personal information that was sold to downstream participants at least 90 days before you opted out, or personal information that was sold by other sources from which you have not opted out.

To submit a request for a list of the categories of personal information collected from you or to request that Capital Pad delete your personal information please send a letter to us at the following address:

Capital Pad

ATTN: Compliance Officer

2028 East Ben White Boulevard
#248-8228
Austin TX 78741

Or by emailing us at privacy@capitalpad.com. 

To verify your request, we may request certain information from you to confirm that you are a Capital Pad user, such as your phone number, username, email address, city, state, or geographic location. You may also designate an authorized agent to make a request to Capital Pad to disclose or delete your personal information. To do so, you must provide Capital Pad with proof that the individual or business has been appointed as your agent, such as by providing a signed power of attorney form and provide accurate responses to any information requested by Capital Pad that may be necessary to confirm that you are a Capital Pad user, such as your phone number, username, email address, city, state, or geographic location. California residents have a right not to receive discriminatory treatment by Capital Pad for their exercise of these rights conferred under California law.

Colorado Residents

Capital Pad does not conduct business in Colorado, control or process the personal data of 100,000 or more consumers during a calendar year, or derive revenue or receive a discount on the price of goods or services from the sale of personal data.

Connecticut Residents

During the preceding calendar year, Capital Pad did not control or process the personal data of at least 100,000 consumers or derive more than 25% of our gross revenue from the sale of personal data.

Montana Residents

Capital Pad does not control or process the personal data of 50,000 or more Montana residents during a calendar year or derive over 25% of its revenues from the sale of personal data and control or processing of personal data of 25,000 or more Montana residents. Therefore, the Montana Consumer Data Privacy Act does not apply to Capital Pad’s collection or use of PII.

Nevada Residents

If you are a resident of Nevada, you may provide notice to us to limit the sale of your PII to third parties for resale or licensing purposes. However, we do not sell your PII for such use. To notify us that you wish to limit the sale of your PII to third parties for resale or licensing purposes, you may contact us at privacy@capitalpad.com. In your submission, please include the statement “Nevada Do Not Sell Request,” along with your name, address, and user account information.

Tennessee Residents

Capital Pad does not exceed $25 million in annual revenue, control or process the personal information of 175,000 or more Tennessee consumers, or control or process the data of 25,000 consumers while deriving more than 50% of its gross revenue from the sale of personal information.

Texas Residents

Capital Pad is considered a small business as defined by the Small Business Administration and, therefore, is exempt from the Texas Data Privacy and Security Act. However, Capital Pad generally collects and processes PII only to the extent that it is adequate, relevant, and reasonably necessary for the purposes disclosed in this Privacy Notice. The categories of PII collected by Capital Pad are disclosed within this Privacy Notice, in particular in Table T.1 above, and Texas residents may request, free of charge, information of the PII collected from them twice annually.

Utah Residents

Capital Pad does not have annual revenues of $25,000,000 or more and control or process the PII of 100,000 or more consumers. Therefore, the Utah Consumer Privacy Act does not apply to Capital Pad’s collection and use of PII.

Virginia Residents

Capital Pad does not control or process the personal data of at least 100,000 Virginia residents or control or process the personal data of at least 25,000 Virginia residents and derive more than 50% of its gross revenue from the sale of personal data. For these reasons, the Virginia Consumer Data Protection Act (VCDPA) does not apply to Capital Pad’s collection and use of PII.  

Global Privacy Control

Capital Pad does not yet recognize Global Privacy Control signals, but it strives to comply with any requests to opt out from the collection and use of PII. Should you wish to opt out from the collection and use of your PII, please contact our Data Protection Officer through the contact information provided in this Privacy Notice.

Changes to our Privacy Notice 

Whenever Capital Pad changes its Privacy Notice, we will post those changes to this Privacy Notice on the Services and other places that we deem appropriate. Your use of the Capital Pad Services following these changes indicates your consent to the practices described in the revised Privacy Notice.

Contacting Us 

If you have any questions about this Privacy Notice or the manner by which we collect or use Personal Information about you, contact us at privacy@capitalpad.com.