We at Geofund, respect your privacy and are committed to protecting any information we obtain from you or about you. This Privacy Policy explains our practices with respect to Personal Data that we collect from or about you when you use our website, services, when you receive our marketing communications or when you engage with us on social networks (collectively, our "Offerings") . By accessing or using our Offerings, you acknowledge that you accept the practices and policies outlined below and consent to our collection, use and sharing of your as described in this Privacy Policy.

What this Policy Covers

This Privacy Policy covers how we treat Personal Data that we collect when you access or use our Offerings in our role as a controller, such as when you visit our website, respond to our marketing, or register for our Offerings. Under privacy laws, "controllers" determine how and why to process personal data (and may also be called "businesses") and "processors" process personal data at the instruction of the controller with which they contract (and may also be called "service providers").

This Privacy Policy does not cover how we treat your Personal Data in our role as a processor to provide our products to our customers. If you are a Geofund customer, your use of our products and our use of your data as a processor is subject to your relevant agreement with Geofund.

If you are a client of a user of Geofund, please direct questions or concerns to the customer, as our customers are responsible for administering their own security practices.

Registered address: 875 15th St NW, Washington, DC 20005, Suite 600

Email: privacy@geofund.com

Personal Data We Collect

We collect personal data related to you ("Personal Data") as follows:

Personal Data You Provide: We collect Personal Data if you create an account to use our Services or communicate with us as follows:

• Account Information: When you register for our offerings, we collect information associated with your account including your name, contact information, account credentials, email, payment information, and transaction history, (collectively, “Account Information”).

• Communication Information: If you communicate with us, such as via email or our pages on social media sites, we may collect Personal Data like your name, contact information, and the contents of the message you send (“Communication Information”). 

• Other Information you Provide: We collect other information that you may provide to us, such as when you participate in our events or surveys. (collectively “Other Information You Provide:).

Personal Data We Receive from your Use of our Services: When you visit, use, or interact with services, we receive the following information about your visit, use, or interactions (“Technical Information”): 

• Log Data: We collect information that your browser or device automatically sends to our Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our services

• Usage Data: We collect information about your use of our Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, type of computer or mobile device, and your computer connection.

• Device Information: We collect information about the device you use to access our Services, such as the name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.

• Location Information: We may determine the general area in which your device accesses our Services based on information like its IP address for security reasons and to make your product experience better, for example, to protect your account by detecting unusual login activity or to provide more accurate responses. 

• Cookies and Similar Technologies: We use cookies and similar technologies to operate and administer our Website and Services. We may store some of the information described in this policy with cookies, for example, to help you maintain your preferences across browsing sessions. For details about our use of cookies, please read our Cookie Policy.

Information We Receive from Other Sources: We receive information from our trusted partners, such as security partners, to protect against fraud, abuse, and other security threads to our Services, and from marketing vendors who provide us with information about potential customers of our business services.

We also collect information from other sources, like information that is publicly available on the internet,  or third party vendors, or partners such as social media platforms, publication, public databases, news sites, or generate leads, create user profiles, or verify your identity.

How we use Personal Data

We may use Personal Data for the following purposes:

• To provide, analyze, and maintain our Services, for example, to respond to your questions.

• To improve and develop our Services and conduct research, for example to develop new product features.

• To communicate with you, including to send you information about our Services and events, for example about changes or improvements to the Services.

• To prevent fraud, illegal activity, or misuses of our Services, and to protect the security of our systems and Services.

• To comply with legal obligations and to protect the rights, privacy, safety, or property of our users, Geofund, or third parties.

We may create aggregated or de-identified Personal Data so that it no longer identifies you and use this information for the purposes described above, such as to analyze the way our Services are being used, to improve and add features to them, and to conduct research. We will maintain and use de-identified information and de-identified in a form and we will not attempt to reidentify the information, unless required by law.

Disclosure of Personal Data

Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services functions, we may disclose Personal Data to vendors and service provides, including providers of hosting services, customer service vendors, cloud services, content delivery services, support and safety monitoring services, email communication software, web analytics services, advertising partners, payment and transaction processors, and other information technology providers. Pursuant to our instructions, these parties will access, process, or store Personal Data only in the course of performing their duties to us.

• Business Transfers: All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part, collectively, a “Transaction”). Your Personal Data may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

• Government Authorities or Other Third Parties: We may share your Personal Data, including information about your interaction with our Services, with government authorities, industry peers, or other third parties in compliance with the law (i) if required to do so to comply with a legal obligation, or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, users, or the public, or (vi) to protect against legal liability.

• Affiliates: We may disclose Personal Data to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Geofund. Our affiliates may use this Personal Data in a manner consistent with this Privacy Policy.

• Account Administrators: When you enroll in a Geofund Service the administrators of your account may access and control your Geofund account, including being able to access your Content. In addition, if you create an account using an email address belonging to your employer or another organization, we may share the fact that you have an account and certain account information, such as your email address, with your employer or organization to, for example, enable you to be added to their business account.

• Other Users and Third Parties you Interact or Share Information With: Certain features will allow you to interact or share information with other users or third parties. For example, you can share and distribute certificate information via our publishing flow. You can also send this information to third party applications. Information you share with third parties is governed by their own terms and privacy policies, and you should make sure you understand those terms and policies before sharing information with them.

We do not sell or trade your personal information.

Additional Disclosures

Some state and geographical laws require specific disclosures. The following table provides additional information about the types of personal information we collect and how we disclose that information. You can read more  about the Personal Data we collect and where we collect it within this Privacy Policy.

Your Data Protection Rights

You have the following rights in relation to your Personal Data:

• Access your Personal Data and information relating to how it is processed.

• Delete your Personal Data from our records.

• Rectify or update your Personal Data.

• Transfer your Personal Data to a third party (right to data portability).

• Restrict how we process your Personal Data.

• Withdraw your consent –where we rely on consent as the legal basis for processing – at any time.

• Lodge a complaint with your local data protection authority (see below).

You have the following rights to object:

• Object to our processing of your Personal Data for direct marketing at any time.

• Object to how we process your Personal Data when our processing is based on legitimate interests.

You can exercise these rights through your Geofund account or our website. If you are unable to exercise your rights through this account, please send your request to privacy@geofund.io 

We hope we are able to address any questions or concerns you may have. If you have any unresolved complaints with us, you can reach out to the appropriate supervisory authority. If you are in the European Union, see see: https://edpb.europa.eu/about-edpb/board/members_en. If you are located in the United Kingdom, you may contact the UK Information Commissioner’s Office (ICO): https://ico.org.uk/make-a-complaint 

Retention

We retain Personal Data about you for as long as necessary to provide you with our Offerings. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Children

Our Services are not directed to, or intended for children under 16 years of age. We do not knowingly collect or solicit Personal Data from children under 16 years of age. If you are a child under the age of 16, please do not attempt to register for or otherwise use the Offerings or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@geofund.io.

Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Legal Basis for Processing

We rely on the following lawful bases to process your personal data:

• Consent: For marketing communications and use of non-essential cookies.

• Contractual necessity: To create and maintain your account and provide our services.

• Legitimate interests” To improve our services, prevent fraud, and understand how our Offerings are used.

• Legal obligation: To comply with applicable laws, such as tax or anti-money laundering requirements.

We do not use your personal data to make automated decisions that have legal or similarly significant effects.

Data Transfers

Geofund processes your Personal Data for the purposes described in this Privacy Policy. While data protection laws vary by country and these countries may not offer the same level of data protection as your home country, we apply the protections described in this policy to your Personal Data regardless of where it is processed. When transferring Personal Data outside of the EEA, Switzerland, or the UK, we rely on the following transfer mechanisms to comply with applicable data protection law:

• We rely on the European Commission’s adequacy decisions⁠ pursuant to Article 45(1) GDPR when transferring your Personal Data to any country that has been considered to provide an adequate level of protection.

• For other jurisdictions, we rely on the Standard Contractual Clauses (“SCCs”) as approved by the European Commission pursuant to Article 46(2)(c) GDPR and on the UK Data Transfer Addendum.

For more information or to obtain a copy of the appropriate safeguards we have in place when transferring Personal Data, please contact us at privacy@geofund.io.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will publish an updated version with a “last updated” date on this page, unless another type of notice is required by applicable law.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@geofund.io or the address provided under the “What this Policy Covers” section (Data Controller).