This Privacy Policy explains how this web site (the "Site"), owned and operated by Globevestor Inc. (henceforward "Globevestor," "we," "us," and/or "our") collects and protects your personal information. If you have any questions that this policy does not address, please contact us at contact@globevestor.com or 55 E 3rd Avenue San Mateo CA 94401.

As explained below, we collect information from you in various ways when you interact with our products and services. By completing your account set-up on our website, you have consented to our collection and use of information as explained in this Notice and agree to be bound by our Terms of Use. Please note that if you choose to invest in any offering advertised on our website, you may be required to agree to a separate agreement, including, but not limited to, new or additional privacy notices or terms of use.

Collection of Information

Globevestor collects Non-Personally Identifiable Information from you regarding your usage of our products and services. Non-Personally Identifiable Information refers to data that does not, by itself, identify individual persons and may include, without limitation, website pages viewed, articles, presentation and videos viewed, time spent using certain features of the website, demographic data such as server locations, cookies existing on your devices used to access Globevestor, search criteria used and results, date, time, connection speed, internet protocol ("IP") address, which may also be contained on server logs, and/or other information which does not specifically identify you. We collect this information using various technologies, including, but not limited to, cookies and server logs. "Cookies" are pieces of information that may be placed on your device by a website for the purpose of facilitating and enhancing your communication and interaction with that website. "Server logs" can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.

Globevestor also collects Personally Identifiable Information from you when you interact with our products and services and communicate with a member of our team, including but not limited to, when you sign up for an account, make an investment, verify your identity, record and verify accredited investor status, provide payment instructions, or send us an email through the Globevestor website or otherwise. Personally Identifiable Information refers to information that allows us to identify you personally. Such information may include, but is not limited to, your email address, name, phone number, birthday, age, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and income, information from your transactions with us (such as your account balance and account usage), information obtained from others (such as the Internal Revenue Service and credit reporting agencies), physical address (such as home or business address), or other information you provide or upload to the website (such as photographs, answers to questionnaires or surveys, or responses filled in on blank forms made available on the site).

We refer to Personally Identifiable Information and Non-Personally Identifiable Information collectively herein as "Personal Data". We may collect and store information, which could include Personal Data, locally on your computer or device using mechanisms such as browser web storage or application data caches. Our collection of Personal Data is necessary to our legitimate interests, which serves as our lawful basis for processing your Personal Data. Such legitimate interests are to run our business, keep our records updated, ensure legal and regulatory compliance, fulfill our obligations, develop our products/services, and inform our marketing strategy.

We will only retain your Personal Data for as long as necessary to fulfill certain legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

We use analytics programs and service providers, such as Google Analytics, which can use first party cookies to report on your interactions with the Globevestor website. Google Analytics collects information including, but not limited to, the time of each of your visits to the Globevestor website, whether you have visited the Globevestor website before, what site referred you to the Globevestor website, and what pages you viewed on the Globevestor website. This Privacy Policy does not cover the collection of information by cookies or other methods by third parties, such as our business partners. We do not control how such third parties collect information or by what means as such third parties may use their own cookies to collect information about you.

Use of Information

Globevestor uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. We will use information you provide to us to better serve you and enhance your experience with the Globevestor website, among other things. This may include having to modify or copy such information, such as images or textual or narrative content you provide, in order to provide you with a seamless and enjoyable experience. Toward these ends, you consent to our use and disclosure of any information submitted to us via the Globevestor website, information collected when you access the Globevestor website in any manner, or information collected through your use of our other products and services, and you acknowledge that you have no expectation of privacy, confidentiality or privilege in such information.

Globevestor will use Personal Data (1) to market our products and services to you, (2) to provide services and products requested by you, (3) to enable our vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of our website and other services, (4) to meet any regulatory requirements for the offer or sale of securities required by law, rules or regulations to our affiliates or members, (5) to engage in any other lawful activities we believe are consistent with the foregoing, and (6) to protect against legal liability. We may provide any of these services through third parties, which may necessitate sharing your Personal Data with them. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Globevestor may also use your Personal Data to help us improve the content and functionality of our website, to better understand our users and to improve our services. Globevestor may use this information to communicate with you regarding our services or to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Note however that as user of our services we will send you administrative communications that are reasonably necessary to our services, such as billing or service notifications.

Globevestor may make your information available on its website and visible to other users of or visitors to the Globevestor website. For instance, subject to certain preferences and permissions as to visibility you will be allowed to make, information you provide about yourself in response to questionnaires on our site may be made available to others, such as information concerning your status as an accredited investor. As such, other users of our website may be able to personally identify you based on your information made available on our site.

We might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. We may also share your Personal Data with our affiliates for purposes consistent with this Privacy Policy.

Globevestor may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Globevestor, (iii) act in urgent circumstances to protect the personal safety of users of the website or the public against fraud or other harm, or (iv) protect against legal liability. Globevestor does not and will not sell any of your Personal Data to any third party for purposes of advertising, soliciting, or telemarketing.

Third Party Websites and Services

The Globevestor website contains links to other websites and services not maintained by Globevestor. In addition, other websites and services may also reference or link to the Globevestor website. We encourage you to be aware when you enter or leave our website, or surf the Internet, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services. We may share your Personal Data with third parties in the following categories, for purposes consistent with those listed above: payment service providers, identity verification service providers, operational service providers (such as for securities and funds custody, transfer agents, broker dealers, data storage, accounting, email, engineering and product development, IT, escrow processing, and invoicing), law enforcement agencies and regulators, and advertising or marketing service providers.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Globevestor other than Personal Data collected through the website. This Privacy Policy shall not apply to any unsolicited information you provide to Globevestor through this website or through any other means. This includes, but is not limited to, information posted to any public areas of the website, such as bulletin boards (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Globevestor shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

Security

We use generally accepted standards to secure access to Personal Data in our possession, including bank-level encryption and account verifications, but will not be liable for any failure to safeguard such information, whether inadvertent or otherwise. We protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. Wherever appropriate, we obfuscate and/or encrypt information in our systems and/or during information transfer. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Blog and Testimonials

Our website offers a publicly accessible blog and other resources. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name and other information. If you wish to remove your personal information from our blog, or update or delete your testimonial, please contact us at contact@globevestor.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Social Media Features

You can log in to our site using sign-in services such as Facebook Connect or Linkedin. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Children

The Globevestor website is not intended for use by children under age eighteen (18 years of age). No one under age eighteen (18) years of age is allowed to use the site, provide any personal information or receive our email distributions. We do not knowingly solicit or collect Personal Data from children or teenagers under the age of eighteen (18). If you believe that a minor has disclosed Personal Data to Globevestor, please report this to us immediately by emailing us at: contact@globevestor.com.

Changes

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this notice at any time. Any changes or updates will be effective immediately upon posting to the web site and/or sending a notification to all registered users via email regarding such update. You should review this notice regularly for changes, and can determine if changes have been made by checking the Effective Date below. Your continued use of our website, products, and services following the posting of any changes to this notice means you accept such changes.

This Privacy Notice was last updated on September 30, 2019.