(i) visitors of Lithium and its affiliates’ websites (e.g., https://lithium.ventures), (ii) individuals who interact with Lithium or its Services, and (iii) individuals who create an account on the Lithium Platform, including “Issuers” and “Investors” (collectively, “users”). You acknowledge and consent to our privacy practices as described below. This policy contains the following sections:
Scope and Applicability Information We Collect and Receive Our Uses of Personal Information How We Share Information Communications and Marketing Data Retention and Disposal Cookies and Other Identifiers Third-Party Sites, Blogs, and Social Media General Data Protection Regulation and International Transfers California Residents Your Privacy Preferences Children’s Data Information Security Breach Notification General Inquiries and Updates
1. Scope and Applicability
2. Information We Collect and Receive
Registered Users—Registered Users are persons who sign up and create a user account with us via the Lithium Platform. We may collect the following Personal Information from Registered Users:
Your name; Your email address; Your username; Your password(s); Your address or geographic location; and Your profile image; Optional Demographic Information including, but not limited to; sexual preference, gender, ethnicity, age, veteran status, disability status, immigrant or refugee status. Investors—Investors are Registered Users (whether natural persons or entities) who have applied to participate in investment opportunities using the Lithium Platform.
We may collect the following additional Personal Information from Investors: Legal physical address; Telephone number; Date of birth; Business name, address, email, phone number, and names of owners and management, if applicable; Balance sheets, profit and loss statements, bank account information, average bank balance, bank statement and other financial data, including tax returns, as applicable, in order to help verify your accreditation status or "Qualified Purchaser" status; Tax ID number or social security number, as applicable, citizenship status, and state or country of formation for investment entities, if applicable; Responses to further questions answered during the profile creation; and Further information in order to help validate your identity such as your driver’s license information or government issued identification number. Issuers—Issuers are Registered Users who have applied to raise capital via a registration exemption using the Lithium Platform. We may collect additional information (e.g., financial and reputational due diligence) as well as that which we would collect from an Investor.
Lithium Platform Visitors—Platform visitors are individuals who access or interact with the Lithium Platform. We may collect or receive the following information about Lithium Platform Visitors:
Log Data: information collected by our servers when you access our websites, including IP addresses, referral URLs, browser type and settings, date and time of usage, language preferences, and cookie data. Device Data: information about your device, including the type of device, the operating system, application IDs, unique device identifiers, and crash data. Analytics Data: approximate geolocation based on your IP address and other information from your browser and device. Contact information: Your name, phone number, email and mailing address, if you engage with us through our contact methods.
Other Webform Data: information collected when you engage with us through our webforms, surveys and questionnaires, blogs, discussion forums, or live chat.
3. Our Uses of Personal Information
To determine demographics of platform usage We use Investor and Issuer Information to:
Verify your identity and status with respect to securities and other laws
Facilitate your payment and any escrow of funds
Record your investment with our third-party SEC-registered transfer agent
Provide you with necessary tax reporting information; and For other purposes for which we provide specific notice at the time of collection of the information. We use Lithium Platform Visitor Information to: Communicate with you and respond to your inquiries
Operate and secure our website and Services; and Analyse and improve our website and Services. Lawful Basis for Processing. Depending on your circumstances and your relationship with us, we may process your Personal Information on the following lawful bases: Consent: where you have given consent to the processing of his or her Personal Information for one or more specific purposes
Contract: where the processing is necessary for the performance of a contract with you (e.g., to deliver the service you have requested)
Legal Obligation: where processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., for compliance with securities laws); and
Legitimate Interests: where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, not overridden by the interests or fundamental rights and freedoms of the data subject, (e.g., for product development and analytics purposes).
4. How We Share Information
Lithium shares and discloses Personal Information to other parties as needed to provide our Services and operate our business. The categories of other parties with whom we may share information include:The Lithium Family of Companies
Affiliates and Subsidiaries.
Lithium may share Personal Information about you with affiliates and subsidiaries. Service Providers. We may share the information that you have provided us with certain third party services, including payment processors, web services providers, developers, security and storage service providers, analytics service providers, and providers used to analyse our websites’ and applications’ functionalities. Business Services. We may share any category of Personal Information with our business services providers in the operation of our business and facilitation of the Services, including agents, auditors, financial institutions, and professional advisors. Corporate Activities. We may share any category of Personal Information with other companies or entities as part of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock. In such case your Personal Information may be transferred to the potential or actual acquirer, successor, or assign. Government and Legal. We may share any category of Personal Information with other parties, including public authorities, as may be required by applicable law, regulation, or legal process.
5. Communications and Marketing
When you sign up for our Services, we will send periodic emails to you regarding the Services or tell you about new Services we believe will be of interest to you; generally, such notices will specify which member of Lithium has sent it to you. You may also subscribe to our blog and newsletter or sign up to hear about investing opportunities. You can also opt out of promotional or marketing email communications, including affiliate marketing, by clicking on the unsubscribe link in any email you receive from us, by accessing your notification settings by logging into your account, or by contacting us. Please note: Opting out will not unsubscribe you from important communications regarding your Lithium Platform account, security related matters or those notices requited by applicable law.
6. Data Retention and Disposal
Lithium retains Personal Information in accordance with its data retention polices consistent with applicable law. Certain Personal Information subject to record retention requirements may be retained for at least 7 years for legal and compliance purposes, as well as with respect to relevant statutes of limitations.
7. Cookies and Other Identifiers
8. Third-Party Sites, Blogs, and Social Media
9. General Data Protection Regulation and International Transfers
International Transfers. Lithium is based in the United Kingdom and your Personal Information may be collected and processed in the United Kingdom. Lithium has affiliates outside of the United Kingdom. If transferred, data is transferred subject to appropriate transfer mechanisms and safeguards. Privacy Rights of UK, EU/EEA, and Swiss Data Subjects. If you are a located in the UK, EU/EEA, or Switzerland, subject to certain limitations, you have the following data protection rights: Withdrawal of Consent. If processing is on the basis of consent, you have the right to withdraw consent to the processing at any time.
Access and Rectification. You have the right to access, correct, and update your Personal Information. Deletion/Erasure. You have the “right to be forgotten” through the erasure or deletion of your Personal Information. Portability. You may have the right to move, copy, and/or transfer certain Personal Information from our service to another service.
Stop Processing. If processing is on the basis of legitimate interests, you have the right to object to the processing of your Personal Information and to ask us to restrict the processing of your Personal Information, subject to certain limitations.
Submit a Complaint. You have the right to submit a complaint to a data protection authority about our collection and use of your Personal Information. Contact details for the UK data protection authorities is located here, for the EU/EEA here, and for Switzerland here.
You may exercise many of your rights through your account or by submitting a request to our Data Protection Officer at firstname.lastname@example.org We will process verified data subject requests within 30 days. If we require more time, we will inform you of the reason and extension period in writing. Please note that requests are subject to appropriate verification before processing.
10. Your Privacy Preferences
Lithium may provide you the opportunity to exercise certain preferences with respect to your Personal Information, such as accessing, updating, deleting, and exporting Personal Information, by logging into your account profile or by making a request to: email@example.com. Lithium may, in its discretion, process such requests as a courtesy, subject to appropriate prior verification.
11. Children's Data
Lithium recognizes the sensitivity of Personal Information concerning children under the age of majority (“Minors”). Our websites and Services are not marketed to Minors and we do not knowingly solicit or collect Personal Information from Minors. If you believe that a Minor has created an account or disclosed Personal Information to us, please notify us immediately at firstname.lastname@example.org
12. Information Security
We take reasonable measures to protect our systems from harm and to safeguard the confidentiality, integrity, and availability of your Personal Information. Our efforts include implementing appropriate physical, technical, and administrative controls to ensure a level of security commensurate with the risk, in particular, to protect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored, or otherwise processed.
13. Breach Notification
If your Personal Information is the subject of a data breach under applicable law or regulation, we will take appropriate action, including providing you with notice, as such law or regulations may require.
14. General Inquiries and Updates