Please see our Privacy Snapshot for a high-level overview of our privacy practices.
What Personal Information We Collect
Passthrough gets information about you in a range of ways.
Information You Give Us. We collect your name, postal address, email address, phone number, username, password, demographic information (such as your occupation), banking information, as well as other information you directly provide on our Site.
Investor Information. If you are an investor or potential investor, we collect certain information about you to allow you to participate in our customers’ fund closings. The information we collect varies based on the fund, but, in addition to the Information You Give Us, it may include your social security/insurance number or other tax identification numbers, government identification documents like passports and driver’s licenses, bank statements, proof of address, your accreditation/qualification status, the amount and source of the capital you intend to contribute to the fund, and contact information of third parties such as joint signers or partners.
Information We Get From Others. We may get information about you from partners and customers. We may add this information to the information you provide to us to make our own information better or more useful.
Information Automatically Collected. We and our service providers may automatically log information about you and your computer or mobile device, and your interaction over time with the Site, online resources, and our communications, such as:
We use the following tools for automatic data collection:
We use your Personal Information for the following purposes or as otherwise described at the time of collection:
We use Personal Information to maintain your account and provide you with related services in accordance with our terms and conditions or other agreement, and to send you information including confirmations, invoices and billing, technical notices, updates, security alerts, and support and administrative messages.
If you reach out to us for support or other questions, it is in our legitimate business interests to use your Personal Information to respond and resolve your queries and facilitate support.
We use Personal Information to authenticate investors’ identities and permit investors to use their authenticated identities to participate in fund closings and other regulated activities, and as otherwise necessary to perform our contract with investors.
It is in our legitimate business interests to operate, improve and keep our Services safe for our users, which includes:
It is in our legitimate business interests to use your Personal Information to contact you and to manage our relationship with you and/or your company where you are a supplier/partner or the representative of a customer/supplier/partner with whom we have a business relationship.
We may use Personal Information for research and development purposes in our legitimate business interests, including to analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from Personal Information we collect. We make Personal Information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
We, our service providers, and our third-party advertising partners may collect and use Personal Information for the following marketing and advertising purposes:
Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time.
We may use Personal Information to comply with legal obligations, and to defend us against legal claims or disputes, including to:
Please note that if you choose not to provide Personal Information requested by us, or refuse our use of your Personal Information, we may not be able to provide you with the services you have requested where this Personal Information is necessary or these services may be delayed.
Passthrough may disclose Personal Information as follows:
Opt-out of marketing communications. You can opt out of receiving Passthrough’s marketing emails at any time by selecting the unsubscribe link in any marketing email we send you, or by contacting us. If you opt out, we may still send you non-marketing emails. Non-marketing emails are service focused and so will generally include emails about your accounts and our business dealings with you.
Online Tracking and Do Not Track Signals: Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Personal Information requests. We offer you choices that affect how we handle the Personal Information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to Personal Information:
To make a request, please email us or write to us as provided in the “Contact Information” section below or use our webform available at https://forms.gle/L1U2z78dmNzUXzp76. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.
Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “Contact Information” section below. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred. In the UK, this is the Information Commissioners Office (ICO) Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Phone number: 0303 123 1113. Website: https://ico.org.uk/make-a-complaint/. If you are based in the EEA, you can find the relevant EEA data protection regulator names and contact details under https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Our Services are not directed to children who are under the age of 18. Passthrough does not knowingly collect information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided information to Passthrough please contact us and we will try to delete that information from our databases.
We implement commercially reasonable technical, administrative, and organizational measures to protect information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no security measures are failsafe and we cannot guarantee the security of your Personal Information.
Passthrough is based in the United States (US) and we use service providers in the US, which means Personal Information you provide to us will be processed and stored in the US. Please note that the US may have data protection laws less stringent than or otherwise different from the laws in effect in your country.
We may share your Personal Information with parties in the US or any other countries that do not have equivalent privacy laws to those that apply in your country of residence. Where required under applicable law, we provide adequate protection for the transfer of Personal Information, including by obtaining your consent, or by putting in place contractual safeguards for the transfer of Personal Information, such as the UK government approved international data transfer agreement/addendum (for UK transfers) and Standard Contractual Clauses approved by the EU Commission (for EEA transfers). Please contact us for further details on the safeguards in place and how to obtain a copy.
UK and EEA Data Protection Representative Contact Information. Please see details of our UK and EEA representatives:
VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
+44 (20) 4532 2003
VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
+420 228 881 031.