Welcome to Nvestly

Nvestly will, among other things, allow an open community of users to share trades and information about securities, markets, companies, securities portfolios and investing. Our mission is to empower people to become better investors. Below you will find our Privacy & Security Policy, but if have any questions you can email us directly at contact@nvestly.com. We’d love to hear from you!

Privacy & Security Policy

Date of Last Revision: February 20, 2017

Nvestly is a software platform wholly owned and operated by Growth Circle, Inc. Growth Circle, Inc. is committed to protecting and respecting your privacy on Nvestly. This Privacy Policy sets out our policies and procedures for collecting, using and disclosing information provided to us by users of Nvestly.com and Nvest.ly ("Nvestly", and, together with any affiliate or partner sites, the "Sites"). This Privacy Policy governs your use of our services and by clicking below, you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. For purposes of compliance with the Gramm-Leach-Bliley Act (the "GLB Act"), this Privacy Policy shall serve as both your initial and annual "privacy notice" as defined under the GLB Act.

If you have any questions or concerns regarding this statement, you should contact us directly at contact@nvestly.com.

Changes to our Privacy Policy

This Privacy Policy may change from time to time. If we make a change to this Privacy Policy that we believe materially reduces your rights, we will provide you with prominent notice on Nvestly or send a notice to you by email. By continuing to use our services after those changes have become effective, you agree to be bound by the revised Privacy Policy.

Nvestly has had its privacy policy and practices reviewed by an accredited third party for compliance requirements including transparency, accountability and choice regarding the collection and use of your personal information. Our third party reviewer’s mission, as an independent source, is to scale online trust among consumers and organizations globally through innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at contact@nvestly.com. This privacy policy only covers information collected on https://nvestly.com and http://nvest.ly.

Information Collected by Us

We collect user submitted account information such as name, email address, and profile photo to identify you and send you notifications related to the use of the services offered by the Sites. We maintain information you submit in your profile on the Sites, and we also collect user submitted content about companies and investing and other information. We collect information from you when you send us feedback as well. Some information collected is not explicitly submitted by the user. Examples of such information include (but are not limited to): browser-type related information, requested URL, referring URL, and timestamp. See "Use of Cookies" below. If you choose to use our Portfolio Dashboard and other related services, we also collect your brokerage account login credentials provided by you and information about your holdings in those accounts.

How We Use Portfolio Information

We never share your personally identifiable information with any advertisers or third parties. Information such as your full name, profile photo and any personally identifiable information you have included in your profile is collected with the primary purpose of maintaining the community of Nvestly users. Such personally identifiable information may be shown to users, primarily in conjunction with any content you have contributed. We also use information supplied to us to respond to your feedback or inquiries. In addition, part of the Nvestly service includes a real time news feed that displays user activity. For example, if you post a trade, a streaming notice may be posted about that activity or the activity of other users. This is part of the Nvestly service and Nvestly users may choose to not participate by not posting such activity. Your full name may also be used when you send an email notification to another user on Nvestly. We may also use your email address to send you communications from us or messages that we send you on behalf of other users, but you may opt out of receiving emails by changing your email preferences in your profile settings.

Service-related Announcements

We will send you service-related announcements on the rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Browser-type related information, requested URL, referring URL, timestamp data, and other information help us diagnose problems with our servers, administer the Sites, and otherwise provide the highest possible level of service to you. In addition, we use this non- personally identifiable information to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the site.

Updating/Accessing Personally Identifiable Information

If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, or delete/remove it by selecting deactivating your account or by emailing us at contact@nvestly.com. We will do our best to respond to your request within 7 days. Please note that even if we close your account, we may retain and use your information as necessary to comply with our legal obligations and/or resolve disputes. Please also note that there might be latency in deleting information from our servers and backed-up versions might exist after deletion.

Use of Cookies and IP Addresses

Like most websites, the Sites and the Partner Dashboard require cookies to function properly. Cookies are small text files that reside on a user's computer and identify you as a unique user. We use cookies to refine our services and simplify the user experience. For example, the use of cookies allows registered users to enter our Sites without explicitly typing in their email address and password every time, and it allows us to personalize your experience on the Sites by, e.g., suggesting content that might be most relevant to you. For these reasons we may tie basic personally identifiable information such as your user name to our cookies. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies might be necessary to provide you certain features (e.g., customized delivery of information) available on the Sites. We use a tracking utility company that uses cookies and Web beacons on our Sites. We have no access to or control over these third party tracking utilities.

Advertising and Partner Sites

We may use third-party advertising companies to serve ads when you visit the Sites. To the extent that we use advertising companies, they may use certain information (not including your name, address, email address, or telephone number) about your visits to the Sites, partner sites and other websites in order to provide advertisements about goods and services that we believe are of interest to you. If you would like more information about this practice and to know your options regarding the use of this information by these advertising companies, please contact us at contact@nvestly.com.

In addition, we may also share data with partners (without any of your personally identifiable information) to aid in monitoring the effectiveness of our product. Such data could include engagement and retention rates with our services and periodic usage metrics reports.

Unless we have your express permission, we will never share any personally identifiable information about you with any advertising companies or with the providers of the advertised goods and services, and these companies will never collect such information on our behalf. If you choose to use these separate goods and services, disclose information to the providers, or grant them permission to collection information about you, then their use of your information is governed by their privacy policies.

Recommendations of Certain Third Parties

We may from time to time recommend third-party broker-dealers to you. If you indicate your interest in learning more about a recommended broker-dealer, we may request your consent to collect information from you, including personally identifiable information, for effective communication to them. The communication of such information to the third-party broker-dealer will be subject to their privacy policy.

Transfer / Disclosure of Information

Some of the information you provide on our Sites is publicly exposed in an aggregated and/or anonymized manner unless otherwise noted. However, except as set forth in this Privacy Policy, we do not sell, rent, share, trade or give away any of your personal information. We do not share your personal information for a third parties’ promotional use. We will disclose information about individual users to governmental or judicial authorities or law enforcement agencies, or to other individuals or entities, in response to subpoenas, court orders, or other legal processes, only as required of us by law. Further, we may share information in order to investigate, prevent, or take action regarding illegal activities or suspected fraud, or to enforce or apply the terms and conditions of this Privacy Policy.

We reserve the right to transfer your personal information in the event of a transfer of ownership of Nvestly, such as an acquisition by or merger with another company. In such an event, we will notify you before information about you is transferred and becomes subject to a different privacy policy.

We will notify you when information about you may be provided to third parties in ways other than explained above, and you will have the option to prevent such information sharing.

Security

Nvestly accounts are password-protected. We use our reasonable best efforts to protect our users' information. If you have any questions about the security on our Sites, please contact us. We follow generally accepted industry standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet or method of electronic storage is 100% secure.

Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that personally identifiable information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.

Email / Direct Mail and Opt-out

Registered members of the Sites can opt-out of receiving personal messages from users or notifications from us by going to the preferences section of the relevant Sites. Unregistered and registered users that do not wish to receive emails may opt-out of receiving any communications by following the instructions contained in all emails from us.

Controlling Your Personal Information

You should be aware that unless you have an profile privacy setting that is set to "private", when you voluntarily disclose personally identifiable information via posts, that information, along with any substantive information disclosed in your communication, can be collected and correlated and used by third parties and may result in unsolicited messages from other posters or third parties. Such activities are beyond our control. If your profile is not set to "private", please do not post any personal information on Nvestly that you expect to keep private.

As a registered user of the Sites, you can modify your personal information at any time by accessing the user settings area Nvestly, as applicable.

Links

Our Sites may contain links to third party websites to which we have no affiliation. Unless you expressly authorize us to do so, we will not share your personal information with such third party websites. We are not responsible for the privacy practices of third party websites and suggest you read any such policies that may apply to you.

Modifications to the Privacy Policy

By using the Sites, you signify your agreement to the terms of our Privacy Policy. If you do not agree with these terms, you should not use any of the Sites. We may modify this Privacy Policy at any time. If a material change is made to this Privacy Policy and / or the way we use our users’ personally identifiable information, then we will post a prominent notice of the nature of such change on the first page of this Privacy Policy. You are responsible for reviewing this Privacy Policy periodically to ensure that you are aware of any changes to it. Your continued use of the Sites or Partner Portfolio Trackers indicates your assent to any changes to this Privacy Policy.

Contact

If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, please send an e-mail to contact@nvestly.com.

Growth Circle, Inc. 6630 Sunset Blvd., Los Angeles, CA 90028