PRIVACY POLICY

First Candidate, LLC, (“First Candidate” or “Company”) provides an intermediary technology platform located at www.firstcandidate.com (“Site”) for prospective investors (each a “User”) to independently search and invest in securities offerings on the Site. The Company may collect information, by various methods, from Users when accessing the Site. By accessing the Site, Users hereby consent to the Company’s collection and use of such information as explained in this Privacy Policy and agree to be bound by the Company’s Terms of Use. If a User chooses to invest in any prospect, project, or offering advertised on this Site, they 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

First Candidate collects non-personally identifiable information from you regarding your usage of our Site (“Non-Personally Identifiable Information”). Such non-personally identifiable information may include, without limitation, a User’s Internet protocol (“IP”) address, the time and duration of their visit, the pages they visit on the Site, information about their browser, device, location, and other information of the type collected by Web servers generally.

This information may be collected through various technologies, including, but not limited to, cookies, web beacons, web session variables, server log files, clear “gifs,” browser plug-ins or add-ons, or Javascript. “Cookies” are pieces of information that may be placed on a User’s computer by a Site for the purpose of facilitating and enhancing their communication and interaction with that Site. A “web beacon” is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a website or in an email which allows a website to record the simple actions of a User opening the page that contains the beacon. “Server logs” can be either a single log file or several log files. Server logs are automatically created and maintained by a server of activity performed by the server, and can include information about any transaction conducted with the server.

When a User registers for an account on the Site, sends an email through the Site, signs up for or purchases services through the Site, or makes an investment through the Site, First Candidate will collect personal information from the User (“Personally Identifiable Information”). Personally Identifiable Information refers to non-public information that personally relates to or identifies the User (such as their name, password, age and date of birth, gender, email address, postal mailing address, telephone numbers, taxpayer identification number, IP address, investment objectives, investment experience, assets and income, and other similar information, or other information such as photographs, answers to questionnaires or surveys, or responses filled in on blank forms, which they have they provided, uploaded, or otherwise made available on the Site. From time to time, the Company may request that Users provide personal information, including, but not limited to, personal or company social media profiles, demographic information, financial information about issues (i.e. valuations, share prices, fundraising goals), financial information about individuals (i.e. net worth), or other similar information. The Company may collect and store information, locally on a User’s computer or device using mechanisms such as browser web storage or application data caches. However, not all information is stored.

The Company may use analytics programs and service providers, such as Google Analytics, which can use first party cookies to report on User interactions with the Site. Google Analytics collects information about Users interaction with the Site including, but not limited to, whether they have visited the Site before, what website referred them to the Site, what pages they viewed on the Site, and the time spent on the Site.

This Privacy Policy does not cover the collection of information by cookies or other methods by such third party services or other third parties, such as our business partners. We do not control how these third party services or third parties collect information or by what means such third party services or third parties may use their own cookies to collect information about a User.

Use of Information

First Candidate will use any information provided to the Company, whether such information is non-personally identifiable information or Personally Identifiable Information, in a manner consistent with this Privacy Policy. First Candidate will use any information you provide to us to, among other things, enhance User experience with the Site. This may include having to modify or copy such User information or content provided by Users, in order to provide a seamless and enjoyable experience.

By accessing the Site, Users consent to the use and disclosure of any information submitted to the Company via the Site, or information collected when they access the Site in any manner, which the Company deems advisable, and acknowledge that as a User you have no expectation of privacy, confidentiality or privilege in such information.

First Candidate may use any information submitted to the Site: (1) to market the Company’s products and services to the User; (2) to provide services and products requested by the User; (3) to serve advertisements on the Site; (4) to enable our vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of our Site and other services; (5) to analyze data to send more targeted messages to Users of our Site; (6) to conduct research and analyze data to improve our products, services, and Site; (7) to deliver email messages like special offers, updates, newsletters, customer service, and service announcements; (8) to verify User information; (9) to comply with and meet any regulatory requirements for the offer or sale of securities required by law, rules or regulations to our affiliates or members; (10) to protect our Site or its Users; (11) to engage in any other lawful activities which the Company has determined consistent with the foregoing; and (12) when required by law or to protect against legal liability. The Company may provide any of these services through third parties, which may necessitate sharing a User’s information, whether Non-Personally Identifiable Information or Personally Identifiable Information, with them.

First Candidate may make User information, other than Personally Identifiable Information, available on its Site and visible to other Users of or visitors to the Site. As such, other Users of the Site may be able to personally identify a User based on the information they make available on the Site. If a User utilizes any third party services to log into the Site, other Users to whom they may be connected through such third party service may be able to view or follow information about them on the Site.

First Candidate may employ or contract third parties, whether companies or individuals to perform certain functions or services on its behalf. Such services may include identity verification, electronic document signing, payment storing and processing, sending postal mail and e-mail, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service. As such, these third parties, companies, or individuals may have access to any information a User supplies to the Site, and which is needed to perform their functions or services, and these third parties may not use such information for other purposes.

First Candidate may also use and disclose any information made available by a User on the Site to help the Company perform certain internal functions such as information management, account processing, client services, or other data collection relevant to our business; to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of the Site or the Company’s network; to protect and defend Company rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of First Candidate’s business or assets. Any successor in interest to our business would acquire the information we maintain, and may alter the terms of this Privacy Policy.

First Candidate does not and will not sell any User information to any third party for purposes of advertising, soliciting, or telemarketing. It may, however, be required to disclose User information to other companies or entities in the event that First Candidate may be sold or is sold to another company or entity. In that case, User information may be sold or transferred to such acquiring, individual, company or entity.

Third Party Sites and Services

The Site contains links to other websites and services not maintained by First Candidate. In addition, other websites and services may also reference or link to the Site. Users are responsible for knowing when they enter or leave the Site, or surf the Internet, and to read the privacy statements of each website and service that they visit. The Company does not endorse, screen, or approve, and is not responsible for the privacy practices or the content of, other websites or services.

Messaging

The Site permits Users to communicate with companies and other Users posting information on the Site. At any time, the Company may read, collect and analyze information transmitted between Users for regulatory compliance and marketing purposes. However, as explained in the First Candidate Terms of Use, the Company relies on the affirmations of investors that they are “Accredited Investors” as defined in the Terms of Use. We do not guarantee that information provided by Site visitors, Users, or investors is accurate or complete. First Candidate assumes no liability or responsibility for any errors or omissions in the content of its Site.

Opt-out Policy

The Company may elect to send e-mail communications with information, marketing or promotional materials to Users and visitors to the Site. Users or visitors who prefer not to receive such e-mails may unsubscribe completely by contacting us through the contact form located at www.First Candidate.com/contact, First Candidate LLC, 2717 Commercial Center Blvd, Suite E200, Katy, TX 77494, chat feature, or by submitting a question through the imbedded “help” button that is processed through Zendesk.

Opt-out requests may take up to five (5) business days to process. Users may not opt-out of e-mail communications that are transactional in nature such as service or termination announcements, or payment confirmations.

Users will have the ability to modify the information in their User account, at any time, by visiting their profile page and editing any information they wish to change. Users may view and change their e-mail address, password, financial information, contact information, or other login information by visiting the account settings page [IS THIS ACCURATE] subject to the Site policies. Users who wish to suspend their account or need assistance with modifying their account information, may contact the Company through the contact form located at First Candidate LLC, 2717 Commercial Center Blvd, Suite E200, Katy, TX 77494, chat feature, or by submitting a question through the imbedded “help” button that is processed through Zendesk. It may require up to five (5) business days to process such requests.

Users will be able to set certain preferences and permissions, in their account settings, regarding the visibility to others, of the information which they share with the Site. Users may stop or restrict the placement of First Candidate’s cookies, Google’s cookies and third party cookies on their computer by adjusting the web browser preferences or selecting a “Do Not Track” setting in their web browser. However, while restricting the use of cookies on their device will not prevent a User from using the Site, this selection may interfere with some of its functionality. Users may clear the cookies from their computer via web browser settings.

Users may request that the Company remove the information they share with the Site from its database by sending a request through the contact form First Candidate LLC, 2717 Commercial Center Blvd, Suite E200, Katy, TX 77494, chat feature, or by submitting a question through the embedded “help” button that is processed through Zendesk.

The Company is not responsible for removing User information from the lists of any third party who has previously been provided with such information in accordance with this Privacy Policy.

Security

The Company will use reasonable efforts to secure access to User information in its possession, but will not be liable for any failure to safeguard such information, whether inadvertent or otherwise. User’s Personally Identifiable Information is also stored with third parties who have informed the Company that they also use reasonable efforts to secure access to User’s Personally Identifiable Information, but it will not be liable for the failure of any third party to safeguard such User information, whether inadvertent or otherwise.

In order to secure User information, the Company employs Secure Sockets Layer (SSL) software which encrypts User information during transmission. Wherever appropriate, the Company will obfuscate or encrypt User information whether such information is stored in our systems or during information transfer.

The Company utilizes third party service providers who may store, on their servers, financial information, electronic signatures, and payment information. Any third parties to whom User information may be disclosed may have their own privacy policies that describe how they use and disclose Non-Personally Identifiable Information and Personally Identifiable Information. Those policies will govern use, handling and disclosure of a User’s personal information once it has been shared with those third parties as described in this Privacy Policy. Users should visit the websites of those third parties and review their privacy practices.

Users agree that it is important for them to protect against unauthorized access to their password and computer, and will endeavor to prevent unauthorized access by parties other than the User, by among other things making sure to log off when finished using a shared computer.

Children’s Privacy Policy

The Site is not intended for use by children under eighteen (18) years of age. No one under eighteen (18) years of age is allowed to use the Site, provide any personal information or receive our email distributions. The Company does not knowingly solicit or collect any information from anyone under eighteen years of age. If you believe that a minor has disclosed Personally Identifiable Information to First Candidate, please report this to the Company immediately by contacting us through the contact form www.First Candidate.com/contact, First Candidate LLC 2717 Commercial Center Blvd, Suite E200, Katy, TX 77494, chat feature, or by submitting a question through the embedded “help” button that is processed through Zendesk.

Changes to This Privacy Policy

The Company reserves the right, in its sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to the Site. Users are responsible for reviewing this Privacy Policy regularly for changes, and determining if changes have been made by checking the Effective Date below. Users consent to and accept such changes through their continued use of the Site following the posting of any changes to this Privacy Policy.

Applicable Law and Jurisdiction

The Site is maintained in the United States of America. By accessing the Site, Users consent to and authorize the export of their Non-Personally Identifiable Information and Personally Identifiable Information to the United States of America and its storage and use as specified in this Privacy Policy.

This Privacy Policy shall be governed by, construed and entered in accordance with the laws of the State of Texas, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Policy shall be brought and heard in either the state or federal district courts located in Dallas, Texas. Users consent to the in personam jurisdiction and venue of such courts. BY ACCESSING THE SITE A USER HEREBY WAIVES THEIR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

Effective Date

This Privacy Policy was last updated on Nov 9th 2016