Revised August 2017
DATA PRIVACY BEST PRACTICES
INFORMATION WE COLLECT
Information You Voluntarily Submit
Neighbor Capital collects any personally identifiable information that you provide to us voluntarily when you register for an account on our Site or choose to make an investment commitment in the offering(s) hosted on our Site.
The exact nature of the information you submit may vary depending on the type of response or service requested. We will only collect information necessary to provide a requested service or respond to an inquiry. The type of information you submit that may constitute personally identifiable information (PII), includes, without limit, the following types of information:
First and Last Name;
Street Address, City, State, Country, Postal Code;
Date of Birth;
Social Security Number
Employment and Income Information;
Valid Day or Evening Telephone Number;
Cell Phone Number;
Confirmation of the age of majority; and
Prior Education History
You are required to create an account to post on Neighbor Capital’s communication channels or to make an investment commitment. As part of the account opening process, we will collect the following information from you:
First and Last Name;
Email Address; and
This information will allow you to post on our communication channels and browse offerings. However, in order to make an investment commitment, you must submit the following identifying information:
Street Address, City, State, Country, Postal Code;
Date of Birth;
Social security number or taxpayer identification number; and
We collect the above information to verify your identity and to detect and prevent identity theft. We also collect basic information about your income and net worth and whether you have invested in any other offerings under Regulation Crowdfunding. We do this because under Regulation Crowdfunding, your annual income or net worth determines the total amount you can invest in all crowdfunding securities in a twelve-month period.
Information We Automatically Collect
Besides information you provide us voluntarily, Neighbor Capital may also collect the following information automatically every time you visit the Site:
- Log Files
Similar to many websites, we gather certain anonymous browsing information automatically and stores it in web server log files. This information includes but is not limited to the following:
Country, State, DMA and City; and
Domain (.com, .net, .mil, .org, .edu, etc.)
We use this information to improve our Site, analyze trends, administer the Site, track users’ movements around the Site and gather aggregate information about our user base as a whole.
A cookie is a small text file that is stored on a user’s computer for record keeping purposes. It can also help us understand how Neighbor Capital Site visitors click through to our Site, and what pages they view during their visit. Similar to many websites, our Site stores an encrypted cookie on your computer so we can remember you when you come back to the Site without requiring you to log in every time. Cookies also allow us to track and understand the interests of our users to enhance the overall experience on our Site.
You can set your web browser software to disable cookies, but this may render the Site unusable to you. To do so, please refer to the help section of your specific browser for more information on how to manage or disable cookies.
Browsers with “Do Not Track” Instructions
The Site does not respond to instructions from browsers where a Do Not Track feature has been activated. The Site automatically collects log file and cookie information from all users.
Neighbor Capital does not knowingly collect or solicit any information from any individual under the age of thirteen absent parental or guardian consent, nor do we direct any of our business practices or system outputs towards children under the age of thirteen.
Neighbor Capital is committed to respecting the privacy of children online and ensuring that the Site is fully compliant with the Children’s Online Privacy Protection Act (COPPA). In the event that we learn we have collected personal information from a child under the age of thirteen without verification of parental or guardian consent, Neighbor Capital will promptly delete any personal information associated with that child as quickly as possible. If you believe Neighbor Capital has information from or about anyone under thirteen years of age, please notify us by email at firstname.lastname@example.org.
HOW INFORMATION IS USED
Standard Requested Services
We may use information collected on the Site to perform the standard services associated with the Site, including to determine your eligibility for offers hosted on the site, to provide you with services you request, to respond to your inquiries; and/or as may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit or security requirements applicable to Neighbor Capital.
In order to improve the experience for our users, Neighbor Capital may offer you the ability to sign up for optional email communications, such as periodic newsletters, updates, or invitations to events. These communications are enhancements to our service and are entirely optional. Neighbor Capital will ask for your consent before sending you promotional communications and will make it easy for you to unsubscribe from these communications.
Identification of Authors
The Neighbor Capital Site may offer opportunities for you to comment on content found on the Site, engage in dialogue, share information and may allow you to submit original content. When you make a contribution to the Site you may be identified by your Site account username or the name under which you choose to post.
We use marketing information to help us better plan our Site and services to meet your needs; to measure and improve our Site’s services and features; to communicate with you by email to provide you with customer support, to prevent potentially illegal activities (including illegal downloading of copyrighted materials in accordance with our Terms of Conditions and Services) and to enforce our Terms of Conditions and Services. We also use a variety of technological systems to detect and address anomalous activity and to screen content to prevent certain abuses such as spam.
Site Statistics, Internal Reporting and Analysis
Neighbor Capital may use information collected from web log and cookie files to analyze and publish anonymous, non-personal, aggregate statistics that may help us to analyze how the Site and its services are being accessed and used, to improve Site performance and delivery, and to analyze and mitigate Site and data security risks. Neighbor Capital may also track and publish anonymized aggregate information, such as the total number of users who have viewed a particular web page. Neighbor Capital will publish this data in aggregate form only and will not tie it to any personally identifiable information.
HOW INFORMATION IS SHARED AND DISCLOSED
On Our Communication Channels
Some of our features may allow you to communicate with other users by posting public messages. Please be aware that what you write in these public messages can be viewed, collected or used by anyone who visits our website. Neighbor Capital is not responsible for any personally identifiable information that you submit or permit others to submit through public messages.
To Third-Party Vendors
From time to time, Neighbor Capital may contract with third-party vendors to support ’s standard business practices and to provide you with a better experience on the Site. Neighbor Capital will only disclose your personally identifiable information to those vendors who also adhere to industry-standard data privacy best practices. Neighbor Capital will never sell your personally identifiable information for marketing or other purposes. Neighbor Capital may also include features whereby you may log in to various third-party social media platforms (for example, Facebook, Twitter or Instagram) while on the Site. Please note that anytime you are logged in to any third-party social media platform, that third-party social media platform may collect information about your browsing habits, including log files or cookie information, or may collect any information you submitted voluntarily. Information collected by third-party social media platforms while you are logged in to those platforms is subject to the privacy policies of those platforms.
Where Required by Law
Neighbor Capital may disclose your personally identifiable information as required by law and where we believe disclosure is necessary to protect our legal rights and/or to comply with a judicial proceeding, court order or legal process served on our Site.
Other than as described above, Neighbor Capital does not share or disclose the information that our Site collects to any other third parties.
HOW TO ACCESS YOUR PERSONAL INFORMATION
You may Neighbor Capital by filling out the form at http://neighborcapital.org/contact-us/ to receive a copy of the personally identifiable information that we may have collected about you for your account.
For California Residents
California Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact Neighbor Capital using the information listed above.
HOW LONG INFORMATION IS RETAINED
HOW INFORMATION IS KEPT SECURE
Neighbor Capital has implemented a variety of commercially standard encryption and security technologies and procedures to protect information, including your personal information, stored in our computer systems from unauthorized access. Please be aware that no method of transmission over the Internet, or method of electronic storage, is 100% secure, thus Neighbor Capital strives to use commercially acceptable means to protect your personal information, but we cannot guarantee its absolute security.
Neighbor Capital also maintains standard physical and electronic procedural safeguards that limit access to your personally identifiable information to our employees (or people working on our behalf and under confidentiality agreements) who, through the course of standard business activities, need to access your personally identifiable information.
YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION
Sharing Information With Other Members
You are able to control what personal information about you is shared with other users and what information you choose to keep private in your use of the Site.
If you subscribe to any optional promotional communications, you will be able to unsubscribe from them through the emails we send you.
THIRD PARTY LINKS
This policy does not cover the privacy practices of any third parties that we do not own or control. We may provide links to other services and on occasion to other sites that may interest you. All of these sites operate independently of Neighbor Capital, and they have their own privacy or security practices. We encourage you to review their policies before submitting any personal information to them.
 Communication channels include but are not limited to public forums, discussion boards or message boards