Effective date: July 29, 2024
The Coterie.Me, Inc. and its affiliates (“The Coterie,” “we,” “our,” and/or “us”) value the privacy of individuals who use our website at www.thecoterie.co, along with our related websites, networks, applications, mobile applications, and other services provided by us (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from or about our users, including any additional users they have authorized to use their account ("Authorized Users") or their devices (users and "Authorized Users" are collectively referred to in this Privacy Policy as “Users”). The Coterie’s mission is to use technology to build innovative financial software products and revolutionize access for a new generation of general partners, fund managers, and investors. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our financial privacy notice, which describes how our financial institution affiliates may collect, use, and share your personal information, our Electronic Disclosure and Consent, and the terms covering your use of our Services, whether it be our Terms of Service or a separate agreement you or your representative has entered into with us (such as a Master Services and License Agreement or other agreement).
Information We Collect
We may collect a variety of information from or about you or your devices from various sources, as described below, including personal information (i.e., information referred to as "Personal Data", "Personally Identifiable Information", "Non-Public Personal Information" or the like by applicable data protection and data privacy laws). If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.
A. Information You Provide to Us.
Registration and Profile Information. When you sign up for an account, we may ask you for your name, email address, phone number, address, title, company, date of birth, taxpayer identification number, place of residency, citizenship status, and any other information we collect.
Payment Information. When you add a payment method to your account, we will receive your personal or business financial account information, such as account numbers or wire transfer information.
Third-Party Account Information. We offer features that allow you to connect and import information from your third-party fund, investment, brokerage, or other similar accounts (“Third-Party Accounts”) to your account on our Services. If you choose to connect such Third-Party Accounts, we may need to collect identifiers and login information necessary to login to your account, such as a username, password, security token, and any other information necessary to connect your accounts and verify your identity. Alternatively, for some Third-Party Accounts, you may be able to connect your accounts by adding The Coterie as an authorized user or named additional party of your Third-Party Account. When you choose to connect your Third-Party Account to your account on our Services through these or any other means, you give The Coterie the authority to act on your behalf to access and retrieve your information from the entity that manages your Third-Party Account and transmit it to us to associate with your account on our Services. The Coterie is not affiliated with or sponsored or endorsed by these Third-Party Accounts.
Other Financial Information. We may also collect:
• Information regarding your status as an accredited investor, a qualified purchaser, and a qualified client, such as your assets, liabilities, employment, income, and expenses that you may provide to us in a certification of your status as such or otherwise in the course of using our Services;
• Investment activity information, such as the specific investment opportunities or transactions that you have chosen to participate in; and
• Information regarding your financial situation which permits us to assess your investment objectives.
Government Identifiers. To use our Services and to help the government fight the funding of terrorism and money laundering activities, we may need to collect government identifiers such as your passport number, driver’s license number, social security number, and Tax ID or other government identifiers. We may also ask to see identifying documents, such as a driver’s license or passport. In doing so, we may receive demographic data such as your age, race/ethnicity or national origin, and citizenship status.
Estate Planning Information. If you choose to use our estate planning product, we may ask for additional information to evaluate your interest in estate planning services and help your estate planning lawyer prepare your trust, such as any gift tax exemption previously used, marital or partnership status, information about your spouse or domestic partner, and information about beneficiaries. Please note that these estate planning services will be performed by your estate planning lawyer and at no time is an attorney-client relationship fostered or created with The Coterie through the performance of any such services.
Communications. If you contact us or our affiliates directly, we may receive additional information about you. For example, when you contact our Customer Support Team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. If we offer a newsletter or similar periodic communication and you subscribe, then we will collect certain information from you, such as your email address. When we send you emails, we may track your response, or lack thereof, including, amongst other things, whether you open them and how you interact with them, to learn how to deliver a better customer experience and improve our Services.
Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. We will collect the information you make available to us on LinkedIn.
B. Information We Collect When You Use Our Services.
Location Information. When you use our Services, we infer your general location information (for example, your IP address may indicate your more general geographic region).
Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, MAC Address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, account name, user ID, and push notification tokens.
Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, purchases you make, and the dates and times of your visits.
Information from Cookies and Similar Technologies. We and third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.
Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
Text Information. In accordance with applicable legal requirements, we work with a third-party partner to facilitate fraud alert text messages between vendors and our users. We receive information about these communications, such as the date and time of the SMS message, the user’s phone numbers, and the content of any SMS messages.
C. Information We Receive from Third Parties.
Other Users. We may receive information about you, including your contact information, from
existing Users who refer you to our Services or who designate you as an Authorized User of their account. We may also receive information about you from the Authorized Users you designate to use your account. Where you are given access to any of the Service through an intermediary User (such as when you are referred to our Service by your fund manager, wealth manager, general partner or other third party), you will also be referred to as an "End User" herein and an intermediary User will be referred to as an "Intermediary" herein. Where we receive your information through an Intermediary, we may also use, share, and handle such information to provide our services to the Intermediary for reasons as provided for in our agreement with such Intermediary and as directed by such Intermediary (as would be covered by the Intermediary's privacy policy and agreement with you, the End User).
Our Banking Partner. The Coterie is not a bank. Bank accounts and services are provided by Grasshopper Bank, N.A., Member FDIC. These services may allow you to open demand deposit and other types of accounts with our banking partners. If you do open such an account, you can use our Services to access your deposit account, view information about your deposit account, and conduct certain deposit account transactions. You may also be given access to various features through our Services separate from your deposit account. If you cancel your enrollment in our Services at any time, we may close your deposit account.
Bank Services related to your deposit account are also governed by the Grasshopper Bank, N.A. Master Service Agreement. Please review this document carefully.Service Providers. We may obtain information about you from our service providers that we use to provide Services to you. For example, our anti-money laundering (AML) and know-your-customer (KYC) providers may provide information to us about you relating to your AML/KYC risk.
Third-Party Accounts. If you choose to connect your Third-Party Accounts to your account on our Services, we will collect information available to you through those Third-Party Accounts including, but not limited to, fund name, capital commitment amount, capital called to date, upcoming capital calls due and due dates, distributions to date, most recent distribution, most recent distribution date, total fund capital, partner percentage of capital, net operating income/loss, management fees and expenses, other income/loss, unrealized gain/loss, realized gain/loss, net investment value, underlying portfolio company names, cost, fair value and investment date (“Third-Party Account Information”).
Credit Report and Background Checks. We work with third-party partners who may provide credit reports and perform background checks on users who sign up for our Services, and receive publicly available information.
Other Third Parties. We may receive additional information about you from other third parties such as Carta and other data or marketing partners and combine it with other information we have about you.
How We Use the Information We Collect
We use the information we collect:
• To provide, develop, maintain, improve, and enhance our Services;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you;
• To facilitate the connection of financial information from your Third-Party Accounts with your account on our Services, such as importing Third-Party Account Information;
• To personalize your experience on our Services such as presenting tailored content, which may include using your information from an investment in one fund to prepopulate subscription documents in another fund in which you choose to invest through our Services or to perform subsequent KYC/AML checks;
• To send you text messages and push notifications;• To facilitate transactions and payments;
• To de-identify and aggregate information collected through the Services, including, but not limited to, Third-Party Account Information, and use and share the de-identified aggregated information for any lawful purpose, including, but not limited to, marketing, analytics, and research. The Coterie will maintain de-identified information in de-identified form and will not attempt to reidentify the information except as necessary to internally assess compliance with this commitment;
• To verify your identity (for example, your data will be shared with telecommunication providers or mobile network operators for the purposes of identity verification);
• To assist our banking partner in determining whether to open a deposit account for you or to verify the existence and condition of your deposit account;
• For Estate Planning Information, to evaluate your interest in estate planning services provided by an estate planning lawyer and to assist your estate planning lawyer prepare your trust (The Coterie does not provide estate planning services directly and at no time is an attorney-client relationship fostered or created with The Coterie through the performance of any such services);
• To find and prevent fraud, terrorism, and money laundering activities; and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected.The laws in some jurisdictions (such as the European Union and United Kingdom) require companies to tell you about the legal grounds they rely on to process your information. Our legal bases for processing your information as described in this Privacy Policy are as follows:Where use of your information is necessary to perform our obligations under a contract or commitment to you. For example, to provide the services you’ve requested from us, or to comply with our legal terms.Where use of your information furthers our legitimate interests or the legitimate interests of others. For example, to provide security for our Services, operate our business and our Services, make and receive payments, defend our legal rights, and prevent fraud.Where we use your information to comply with applicable legal obligations. For example, keeping track of purchases for auditing and anti-money laundering purposes.Where you have consented to our processing of your information for a particular purpose.How We Share the Information We Collect
We may share or otherwise disclose information we collect from or about you as described below or otherwise disclosed to you at the time of the collection.
Affiliates. We may share any information we receive with our corporate affiliates for any of the purposes described in this Privacy Policy. For example, we may share information we collect from or about you with our Affiliates:
• To select and close on transactions in which you have chosen to invest. For example, we use information that you provide to us regarding your interest in a particular offering in order to gauge whether sufficient interest exists to fund a particular investment opportunity.
• To comply with applicable laws and regulations. For example, we use information gathered in your investor questionnaire to help ensure that we are offering our investment opportunities consistent with the requirements of federal and state securities laws and regulations.
• To help us inform you of investment opportunities. For example, we use information about your prior investments to assist us in determining subsequent offerings in which you may be interested.
Authorized Users. If you designate another individual to have access to your account ("Authorized User"), you acknowledge and agree that the Authorized User will have access to your account and all personal, financial, and other information contained therein, and may view, copy, download, and disclose the information in your account in their discretion. You also agree that the Authorized User will have the ability to utilize all of the same functionalities in your account as you can, including the ability to make investments on your behalf, create an entity, change security and entity settings, begin and complete financial applications, and transfer funds. You can withdraw an Authorized User's further access to your account at any time by emailing us at help@thecoterie.me, but you understand that withdrawal of this authorization will not result in interruption in any transactions in which the Authorized User has already engaged through your account and that the Authorized User will still retain copies of your information that they downloaded or copied prior to the withdrawal.
Transaction Partners and Service Providers. We may share any information we receive with transaction partners and service providers retained in connection with the provision of our Services, including bank partners, fraud, credit and compliance risk data providers, and banking technology partners.
We may share any information we receive in one or more of the following circumstances:
• We may disclose personal information with individuals and entities who are involved with a specific transaction.
• We may disclose personal information about you to third parties for servicing and processing transactions, to comply with the requests or instructions of our regulators, to protect against fraud, for risk control, or to perform services on either your or our behalf.
• We may disclose your personal information to companies that provide services to us, such as our attorneys, accountants, and auditors.
• Our transaction partners and service providers may assist us in processing transactions, handing deposit account operations, and providing technological connection to our banking partner. In particular, Increase Technologies, Inc. or a company that provides similar banking technology services may perform any functions on your deposit account that we are otherwise authorized to perform. Access and use of your information by Increase Technologies, Inc. is governed by its Privacy Policy, available at https://increase.com/privacy.
Your Estate Planning Lawyer. We may share your Estate Planning Information with your estate planning lawyer to facilitate the lawyer’s preparation of your trust. At no time is an attorney-client relationship fostered or created with The Coterie through the performance of any such services.
User Content. Our Services may allow users to post messages to other users within the Services and privately message other members. Your name, username, and other profile information will then always be viewable and searchable by other users. We are not responsible for the other users’ use of messages you post, so you should carefully consider whether and what to post or how you identify yourself on the Services.
User Referrals. When you refer someone to our Services through our referral program, we let your referral know that you referred them. Likewise, if an existing User referred you to our Services and you sign up for an account and make an investment through our Services, we let the referring User know that you made an investment when they receive credit for the referral through our referral program. If you receive a referral from another User but would rather decline the referral, please contact us via the Contact Information section below.To Your Intermediary. Where you are an End User, we provide relevant information to your Intermediaries to provide services to your Intermediary based on our agreement with such Intermediary.
Marketing. We do not rent, sell, or share information about you with non-affiliated companies for their direct marketing purposes, unless we have your permission.
Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For example, we may be required by law to provide to the federal government information about the identity of our investors, as well as their individual receipts of income and gross proceeds pursuant to Sections 1471-1747 of the United States Internal Revenue Code. For the avoidance of doubt, the disclosure of your information may also occur if you post any objectionable content on or through the Services.
Merger, Sale, or Other Asset Transfers. We may disclose and transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets.
Consent. We may also disclose information from or about you or your devices with your permission, including when you give someone power of attorney or other authorization to act on your behalf.
Your Choices
Financial Information. You have the right to restrict the sharing of personal and financial information with our affiliates (companies we own or control) and outside companies that we do business with. To exercise this right, review our financial privacy notice and fill out, sign, and send back the form on page 3.
Location Information. You can prevent your device from sharing precise location information at any time through your device’s operating system settings.
Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.
User Referrals. If you receive a referral from another User but would rather decline the referral, please contact us via the Contact Information section below.
Third Parties
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
Security
We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.
Children’s Privacy
We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at privacy@thecoterie.me.
International Users
Our Services are hosted in the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, you acknowledge that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you agree to such transfer, storage, and processing.
Your Rights and ChoicesWe provide you with the ability to exercise certain controls and choices regarding our collection, use, and disclosure of your information. Depending on the laws in your jurisdiction of residence (e.g., California, EU, or UK), you may request: Access to, or a copy of, your information in a structured, commonly used and machine-readable formatCorrection or rectification of your informationDeletion of your informationRestriction or objection to certain processing of your informationTo withdraw your consent to our use of your information for certain processing purposes, where the processing purpose was based on your consent Please note that we do not use your information to make decisions that produce legal or similar effects based solely on the automated processing of your information. We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests. For example, depending on the Services you were using, whether you are an End User, and the type of information we maintain about you, we may need to keep your account open or retain some or all information associated with your account after deletion to comply with the terms of our agreements with you or a third party (including the agreement we have with your Intermediary where you are an End User), our legal obligations, our legal rights, for security purposes, or where we have deidentified or aggregated that information. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process. To make a request, please email us at help@thecoterie.me. You can also update your account and profile information through your profile settings.
Changes to this Privacy Policy
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through our Services, we will notify you through our Services, by email, or other communication.
Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at privacy@thecoterie.me or write to us at The Coterie, 77 Geary Street, 5th Floor, San Francisco, California, 94108.
