Privacy Policy
Updated 8/7/2020
Updated 8/7/2020
This Privacy Policy (the “Privacy Policy”) describes our information collection and use practices of CommonStock, Inc. (“CommonStock,” “we,” “our,” or “us”) in connection with our Website, App and Platform that allows friends, family and experienced investors to share their investment knowledge with community Members and chat in groups about their Investments, including securities and certain Virtual Currencies, and to buy, sell, and invest together.
Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.
In the course of operating the Website, the App, and thePlatform, we may collect the following types of information.
When you register for the Platform to create an account, or contact us, you will be required to provide us with information about yourself (the “Personal Information”). Such Personal Information may include your name, address, e-mail address, phone number and other information. We may also collect information that you voluntarily provide to us, such as household income range, personal interests, and product and service preferences. If you register for the Platform using your Facebook or any other social media account provided by a social media service, we may collect, store, and use any and the information provided to us by the social media service in accordance with the terms of its privacy policy. Such information may include, without limitation, your first and last name, username, profile picture, unique social media identifier and access token, and e-mail address.
As a Member, when you make a Transaction, we will collect information about your Transaction, including the date and time of the Transaction, the Transaction amount, the securities and/or Virtual Currencies purchased or sold, the Brokerage Account and third-party broker-dealer or cryptocurrency exchange involved in the Transaction, pending status, and related information about the Transaction (the “Transaction Information”).
As part of using the platform, you will be given the option to link your Brokerage Account to your CommonStock account. This will allow you to make Transactions via the Platform. CommonStock does not collect or obtain access to your payment information, including credit card information. Rather, such information is collected by your third-party broker-dealer or cryptocurrency exchange pursuant to your Brokerage Account’s privacy policy.
We may collect additional information automatically when you visit and/or use the Platform including your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Platform, information about the links you click, and other information.
In addition, we may collect data regarding your use of the Platform, such as the types of content you interact with, information derived from your Groups and your User Content (including other Members with whom you interact, topics you discuss with your Groups, and anything else that you post or interact with via the Platform) and the frequency, duration, and timing of your activities. We may combine your information with information that other people provide when they use our Platform.
We, as well as third parties that provide content, advertising, or other functionality on the Platform, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Platform. Technologies are essentially small data files placed on your devices that allow us and the third parties to record certain pieces of information whenever you visit or interact with our Platform. Cookies are small text files placed in web browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Platform may not work properly. A pixel tag (also known as a web beacon) is a piece of code embedded in the Platform that collects information about engagement on a web page. The use of a pixel allows us to record, for example, that you have visited a particular web page or clicked on a particular advertisement.
We may also use Google Analytics and other service providers to collect information regarding behaviors and demographics on the Platform. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Platform by going to http://tools.google.com/dlpage/gaoptout.
We use the Personal Information, Transaction Information, and Other Information (collectively, “Information”) for a variety of business purposes, including to provide you with access to the Platform and the services available on the Platform, including to:
Your Transaction Information is automatically made public to all Members of Commonstock and any and all Groups, Channels, or Direct Messages in which you are a Member. You may adjust the amount of Information that we share with other Members by visiting your personal privacy settings; provided, however, that it is the purpose of the CommonStock Platform to provide an opportunity for Members to share their Investment activity with other Members, and, therefore, certain aspects of your Transaction Information cannot be made private.
We will share your Information with third-party broker-dealers and cryptocurrency exchanges in order to execute Transactions.
In an ongoing effort to better understand our users and our Platform, we may analyze the Information in de-identified and/or aggregate form in order to operate, maintain, manage, and improve the Platform. This de-identified and/or aggregate information does not identify you personally. We may share, sell, and/or license this de-identified and/or aggregate data with our affiliates, agents, and business partners, and other third parties. We may also disclose aggregated user statistics in order to describe our products and Platform to current and prospective business partners and to other third parties for other lawful purposes.
We may employ other third parties to perform functions on our behalf. Categories of third parties include companies and individuals providing marketing assistance, information technology support, ID verification, purchasing and selling securities and Virtual Currencies, maintaining databases, and customer service. Our agreements with these third parties will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
We may share your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
We may share Other Information about your activity on the Platform with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Platform and elsewhere.
Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
To the extent permitted by applicable law, we may also disclose the Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us, our users, or others.
You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on the Platform and for other legal purposes as described above.
We will not share, disclose, or sell your Personal Information or Transactional Information with non-affiliated third parties that may use such information to market to you, without obtaining your opt-in consent. For example, we may offer you a product opportunity that requires us to share your Personal Information or Transactional Information with non-affiliated third parties that may use such information to market to you. We will obtain your opt-in consent to such sharing of your Personal Information or Transactional Information when we present you with the terms of such offer. If you have opted-in for this kind of sharing, then you may: (i) choose to opt-out of such sharing by contacting us as set forth below; or (ii) request certain information regarding our disclosure of such information to such non-affiliated third parties by contacting us as set forth below. Further, if you would like to opt-out of CommonStock’s sharing of your Information with its affiliates so that such affiliates can use your Information to market to you, please contact us as set forth below.
You may access, review, and make changes to your Personal Information by following the instructions found on the Platform. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any CommonStock marketing email. Members cannot opt out of receiving transactional e-mails related to their account; however, you can delete your account and/or change your email.
We may send you push notifications through our mobile application. You may at any time change your preferences from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may update this by changing the settings on your mobile device.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please log into your account or contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
We store the personal information we receive as described in this Privacy Policy for as long as you use the Platform or as necessary to fulfill the purpose(s) for which it was collected, provide our services on the Platform, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We maintain physical, electronic, and procedural safeguards that comply with applicable state and federal laws and regulations to guard non-public personal financial information from unauthorized access, use, and disclosure. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information you supply will not be intercepted while being transmitted to and from us over the Internet.
The Platform and our servers are operated in the United States. Please be aware that your Information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Platform, you do so at your own risk.
The Services are not directed to children under 16 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
CommonStock does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
The Platform may contain links to third-party websites. CommonStock has no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will notify you as required by applicable law and post any changes on the Platform as soon as they go into effect. By accessing the Website or app or using the Platform after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.
If you have questions about this Privacy Policy, please e-mail us at help@commonstock.com.
Commonstock, Inc
735 Montgomery St, Suite 400
San Francisco, CA 94123
Commonstock is a social network that amplifies the knowledge of the best investors, verified by actual track records for signal over noise. Community members can link their existing brokerage accounts and share their real time portfolio, performance and trades (by percent only, dollar amounts never shared). Commonstock is not a brokerage, but a social layer on top of existing brokerages helping to create more engaged and informed investors.
