Privacy Policy / Terms Of Use

Introduction

The crowd-investing technology platform at www.prodigynetwork.com, including any subdomain thereof (the “Site”) maintained by Prodigy Network, LLC ("Prodigy Network", “The Company”, “we”, "our" or “us”), was created to provide you with information about our service, including our investment services and the content, services and/or products provided through our Site (collectively, the “Service”). We value the privacy of our Service visitors (“you,” “your,” or “User”), and in order to protect your personal information, we have implemented the following Privacy Policy with provisions that apply to the collection of data by us, our subsidiaries, and our affiliates. If you have questions or concerns regarding this statement, you should first contact us at support@prodigynetwork.com.

This Privacy Policy, effective on May 1st, is part of our Terms of Service and discloses the type and nature of information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any requests for personal or personally identifiable information will be used. Finally, we present our security policy, which outlines how your personal information is protected. Each time you access, use, register with, or browse the Prodigy Network Site you expressly consent to Prodigy Network’s then-current Privacy Policy, and the policies and practices described therein.

Please note that we may update our Privacy Policy from time to time. Any revised policy will be effective from the date stated in the revised Privacy Policy. We recommend that you check our Privacy Policy frequently to see recent changes to our Privacy Policy.

Information We Collect

We collect personally identifiable and non-personal information from you when you visit the Site. The majority of information is collected during the registration and/or application process and, while some items are optional, most are required for legal or security purposes. You may choose to provide additional information during subsequent visits to the Site, but keep in mind that some of this information will be required if you wish to partake in the Services.

In general, the type of information we collect includes, but is not limited to:

  • Personal data required to verify your identity;
  • Personal and financial data necessary to assess your eligibility to utilize the Services on the Site; and
  • Non-identifiable and aggregated personal data pertaining to your Site visits that help us maintain the appropriate features, functionality and User experience (including IP address, your login data, time zone setting, browser plug-in types and operating system and platform and other technology on the devices you use).

We do not collect any special categories of data for the purposes of GDPR (this includes details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offenses. This Privacy Policy is not intended for children and we do not knowingly collect personal information relating to children.

Upon registration, the Prodigy Network Site will ask you to allow it to have access to and import your contacts stored in your mobile or relevant device (the “Contacts”). If you agree, Prodigy Network will import the information of all of the Contacts. By agreeing to allow Prodigy Network to have access to and to import your Contacts, you are agreeing to share any and all contact information in your Contacts with Prodigy Network. By allowing Prodigy Network to access your Contacts, you agree that Prodigy Network may reach out to your Contacts and invite them to join Prodigy Network. You agree that by sharing your Contacts,. yYou are legally authorized to share such information. You agree to hold Prodigy Network harmless and indemnify us from any damages, including attorneys’ fees and court costs, resulting from your unauthorized sharing of information.

Personal Data

Investor registration applications will require you to provide basic personal data. Such information may include your name, email address, a password, answers to security questions, home address, primary business address, country of residence, citizenship, information about your income and net worth, phone number, date of birth, social security number and/or tax identification number, employment status and job title, bank account information, passport number and expiration date, a copy of your valid government issued Photo I.D., educational history, investment knowledge and experience, central registration depository number if applicable, and other similar information.

We use this data to: (i) enable you to log in to the Site; (ii) establish your ability to view offering materials and to make investments through the Site (e.g., “accredited investor” status); (iii) verify that you are at least 18 years of age; (iv) guard against potential fraud; (v) contact you if there is a problem with your account; and (vi) maintain regular communications with you as may be necessary to inform you of upcoming investment opportunities and other Company updates.

We will also gather the names and email addresses of Users who contact us through the Site with questions about our Company or Site. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested to do so, as in the case of job applicants who submit resumes.

Financial Data

When you subscribe to make an investment in one of our offerings on the platform, you will again be asked for your personal data. You will also be required to provide financial data, such as your bank routing number or swift code, and bank account number, to help to facilitate the subscription process.

Non-Identifiable Data and Aggregated Personal Data

Regardless of whether you register for an account or submit an application, we may send one or more “cookies” to your computer. Cookies are small text files placed on your web browser when you visit our Site that store information on your computer, such as your Site preferences. We use cookies when you sign in to keep track of your personal session, including some account identifiers to ensure that you are the only person making changes to your account. We also use cookies to track your activity on the Site as a unique person. For security purposes, all of this information is stored in encrypted form. No personal information about you is stored.

You can set your web browser to inform you when cookies are set, or to prevent cookies from being set altogether. Please note, however, that if you decline to use cookies, you may experience reduced functionality and slower site response times. In some instances, declining to use our authentication-related cookies may prevent you from using the website entirely.

We, or our service providers, may also collect web surfing data related to your use of the Site. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; the dates and times that you visit the Site; and general geographical location. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any Users as individuals.

Web surfing data and similar information may be aggregated for administrative purposes. Aggregated information may be derived from your personal information but is not considered personal data in law as this data does not directly or indirectly reveal your identity. We may, for example, use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies, and other marketing activities. We also use it to help optimize the Site based on the needs of our Users.

How and When Your Information Is Shared With Other Parties

We do not sell or rent personal information about our Users for marketing purposes. We do, however, share your personal information with our trusted partners who perform vital functions with respect to the investment opportunities on our Site. We require all our trusted partners to respect the security of your personal information and to treat it in accordance with the law. We do not allow our trusted partner service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

In addition, your investment profile information may, in a generic way, be made publicly available for use on the “Statistics” page of the Site or in other summaries of aggregate investment data.

If you use our blog on the Site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other Users of this forum and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit through this forum.

Additional Sharing of Investor Information

We also work with (among others) providers of hosting services for the Site, electronic signature providers, and electronic payment service providers. We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing, reporting, tax documentation, custody or escrow services. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform, as well as other specific services, like collections. Our partners are legally required to keep your information private and secure.

We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, legal process, government request, or to comply with any applicable law or regulation, foreign or domestic. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or the Service, or to protect the rights, property or personal safety of the Company, its Users, issuers, or others.

By utilizing the Prodigy Network Site, you hereby give us the right to produce any and all messages or user content of any kind produced by you to county, state, and federal courts and/or government officials in response to a subpoena or other court order in the U.S., or in response to similar requests in other jurisdictions.

Change of Control

In the event that Prodigy Network is merged or sold, or in the event of a transfer or sale of some or all of our assets, we may disclose or transfer information we collect in connection with the negotiation and/or conclusion of such a transaction.

Notifications and Communications from Our Site

We will send you email notifications from time to time. Some notifications are required elements of your transactions on our platform, such as confirmations of particular actions you have taken. These mandatory notices are sent typically to notify you of a change in status. For example, you will receive a notice when you are confirmed as an investor.

We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that another person cannot make a change to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or Site policies. Generally, you may not opt out of such service-related emails.

When you register as an investor, you will receive emails that confirm specific actions you requested. These will include emails to which you must respond to complete your registration and notifications confirming your registration. Thereafter, you will receive emails when a new investment opportunity is offered, as well as updates concerning the progress of the funding of such offering and/or other relevant information. If you make an investment through the Site, we will also send you confirmations of the investment as well as occasional updates as to the status of that investment and the timing of distributions relating to that investment.

We may also send you responses to emails you send us, if appropriate. From time to time, we will also send User surveys, requests for User feedback regarding User experience and Site operations, or marketing offers from us or from us on behalf of our marketing partners. Completing these surveys, answering requests for feedback, or accepting any offer is strictly voluntary. If you do not wish to continue receivinge these surveys, User feedback emails, and/or marketing offers, please opt out in any offer email you receive from us.

Where You Can View and Correct Your Information

We urge you to review your information regularly to ensure that it is correct and complete. If you believe that any of your information is incorrect, or if you have any questions regarding this Privacy Policy, please contact us at support@prodigynetwork.com.

Links to Other Sites

If you follow any links that direct you away from the Site, this privacy policy will not apply to your activity on the other websites you visit. Clicking on those links or enabling those connections may allow third parties to collect and share data about you. We do not control the privacy policies or the privacy practices of any third parties. We encourage you to read the privacy policy on such third party websites.

International Users

The Site may be accessed by Users located outside of the United States. If you choose to use the Service from the European Union, Latin America, or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States, and that by providing your personal information on or through the Site, you consent to that transfer and to the extent permissible, waive your right to the protections of any local non-U.S. laws. We will ensure that appropriate data security measures are in place when your data is transferred to the United States.

Security Policy

Access Limitations

We limit access to the personal information we have about you to those employees and other persons who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. The Site is built upon a secure infrastructure with multiple layers of protection, and we use industry-standard encryption technologies to safeguard your information.

Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Site. Generally, identification and authentication take place through the use of your username and a password and/or while logging in with one of our support staff.

Notifications of Security Systems Breach

If we learn of a security systems breach, then we will attempt to notify you electronically or in writing so that you can take appropriate protective steps. We will also notify any applicable regulator of a breach where we are legally required to do so and may also post a notice on or through the Site in the event of a security breach.

Take Precautionary Measures

You can take several precautions to protect the security of your computer and personal information. For instance, you can use a well-chosen password and restrict access to your email account. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious Users. When you are finished with a session on the Site, be sure that you log out and close the browser window.

You should also be aware of fraudulent attempts to gain access to your account information through "phishing," whereby scammers try to bring unsuspecting people to a website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on this fake site, scammers will ask for login information to gain access to people's accounts and withdraw their money.

We will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go the website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain. In the case of the Company, you should always ensure the URL begins with https://www.prodigynetwork.com.

Transmissions over the Internet are never 100% secure or error-free. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal information to Prodigy Network or through Prodigy Network Services via the Internet.

Data Retention

We will only retain your personal information as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. When determining the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your Legal Rights (EU Residents)

If you are a European Union resident, under certain circumstances you will have rights under data protection laws in relation to your personal information, including the right to request access to your personal information, the right to request correction of your personal information, the right to withdraw consent and the right to request erasure of your personal information. If you wish to exercise any of your rights, please contact us using the contact information provided below in the “Contact Us” section.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your legal rights). This is a security measure to ensure that your personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex, or if you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal information (or to exercise any of your other legal rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Other Agreements

Your access to and use of this Site is subject to Prodigy Network’s Terms of Service available here.

Contact Us

If you have questions or comments about this Privacy Policy, your choices with regards to our collection and use of your User Information or any other aspect of the Site or Services, please feel free to contact us by email at: support@prodigynetwork.com.

Right To Opt-out. If at any time you wish to opt-out of the above Privacy Policy, you may do so at any time by contacting us by email at: support@prodigynetwork.com. If at any time you so decide to opt-out by contacting us at the above email, Prodigy Network will cease the sharing or use of your information after a reasonable amount of time to process such a request. However, please be advised that certain of our Services, including but not limited to our investment platform, require the sharing of your information in order to service your activity on our site. In such a case, it may be necessary for us to terminate your use of such services.