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Privacy Policy

Effective Date: February 8, 2017

Your privacy is important to us at QuarterSpot, Inc. (hereinafter “QuarterSpot,” “we” or “us”). This Privacy Policy describes the types of information we gather, how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through our website at www.quarterspot.com (the “Website”). These explanations can usually be found on the same pages where the information is requested.
By using the Website, and the functionality, data, information, updates, and similar materials delivered or provided through or by the Website (the “Services”), you hereby consent to allow us to process information in accordance with this Policy. Please also refer to our Terms of Use, which are incorporated as if fully recited herein. The use of information collected through our Services shall be limited to the purpose of providing the Services for which our customers have engaged Quarterspot.
If our information retention or usage practices materially change, we will let you or our Clients know by posting notice of the Privacy Policy changes on the Website, and we may contact you regarding this via email prior to said changes becoming effective. Please refer to the “Effective Date” above to see when this Policy was last updated.
If you have questions or complaints regarding our privacy policy or practices, please contact us at support@quarterspot.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
As described in greater detail in this policy, we collect several types of information from you and/or your business:
If you register as an investor, we collect:
  • Personal information to assist us in verifying your identity;
  • Personal and financial information to allow us to assess your eligibility to invest on QuarterSpot;
  • Optional personal information you may wish to share with QuarterSpot in order to better use our Website or Services; and
  • Information about your visits to the Website and use of the Services to allow us to better tailor the site to our investors.
If you register as a borrower, we collect:
  • Business information required to verify the identity of your business;
  • Financial information and documentation necessary to assess a business’ eligibility to borrow money through QuarterSpot;
  • Optional business information you may wish to share with QuarterSpot in order to better use our Website or Services; and
  • Information about your visits to the Website and use of the Services to allow us to better tailor the site to our borrowers.
Territoriality
Regardless of where our servers are located, your data will be processed by us in the United States, where data protection and privacy regulations may not be to the same level of protection as in other parts of the world. BY VISITING THIS WEBSITE OR USING THE SERVICES, YOU UNEQUIVOCALLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH YOUR USE OF THE WEBSITE OR SERVICES, AND YOU ALSO AGREE THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.
Information Related To Data Collected Through QuarterSpot Services
QuarterSpot may collect and process personal information of both investors and borrowers under the direction Clients working on behalf of the investor/borrower. QuarterSpot acknowledges that you have the right to access your personal information. In these cases, we have no ownership of the information or any direct relationship with those individuals whose personal information may be processed as part of providing our Services. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. For example, we may notify third parties if you are eligible to refinance your loan or obtain additional financing. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
An individual who seeks access to their data, seeks to correct, amend or delete inaccurate data or wishes to opt-out of communications from a QuarterSpot Client should direct his/her query to the QuarterSpot Client he/she interacts with directly. If a QuarterSpot Client requests that we remove or access personal information on their behalf, we will respond to their request within 30 days.
QuarterSpot will retain personal information we process on behalf of our Clients for as long as needed to provide services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Information We Collect From You and About You
When you use our Website and Services, we collect personal information from you and, if registering as a borrower, financial information and documentation about the business to which you are an authorized representative. The majority of the information we collect occurs during registration. Some information is required and some is optional; as identified, some will remain private and some will be displayed to other users. Further information may be collected during your use of the Website and Services, as described in this policy.
The first step in using our Website and Services as an investor or a business is user registration. New users must first register as QuarterSpot users. Certain personal information must be supplied during sign-up procedure, as indicated below. This information is needed to (1) allow registered users of the Website and Services to login (2) generate an online screen name, (3) verify users’ identities and age eligibility, and (4) guard against potential misuse of the Website and Service.
This basic personal information we collect includes:
  1. Your name;
  2. Your email address;
  3. Your phone and fax number;
  4. Your date of birth;
  5. Your home address; and
  6. Your Social Security number.
To become an investor on our platform, we will request some required and optional data such as your bank account in order to:
  • Determine whether you qualify as an Accredited Investor under Rule 506 of Regulation D of the Securities & Exchange Act;
  • Enable our financial services partners to implement fund transfers and the receipt of borrower payments; and
  • Maintain regular communications with you, including communications regarding transactions you request, such as transferring funds, etc.
To become a borrower on our platform, we will request some required and optional data in order to:
  • Determine the business’ eligibility to become a borrower on QuarterSpot and obtain loans through our platform;
  • Pull a report from a credit bureau to determine the creditworthiness of your business;
  • Assign ratings to your loan request;
  • Help investors evaluate whether to invest in your loan listing;
  • Enable financial services providers to make automatic fund transfers and payments;
  • Facilitate collection activities as needed; and
  • Communicate with you, including regarding transactions you initiate, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.
Information We Collect About Third Parties
We collect the names and email addresses of people who contact us through the Website and Service.
If you use our Website or Services to share our content with others, we may collect the contact information of the party with whom you wish to share such information. We may send that contact information a message inviting them to visit our Website or use our Services. After collection, you or your contact may email us at support@quarterspot.com to opt-out of this use. QuarterSpot stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.
Referrals
Users of the Website and Services may refer contacts via e-mail to the Website and Services in general, or to the area of the Website or Services where such users’ loan listing appears. If this referral occurs through our Website or Service or those of our associates, we may track and store information about such referral sources and referrals. We may use this information to send the communication, for internal operations, to effectuate bonuses or incentives, if any, and to assess our efforts. In addition, we may collect information about third-party businesses for credit reporting agencies in order to assess creditworthiness and transactions on the Website and Services.
Testimonials
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at support@quarterspot.com.
Communications From QuarterSpot
By participating in the Website or Services, you will be contacted by QuarterSpot from time to time. Such communications may include emails regarding confirmation of actions, progress updates, and other administrative communications from us. You cannot opt out of these communications.
With your consent, we may contact you with surveys, requests for feedback or offers from us or our associates. Out of respect for your privacy, you may choose to stop receiving the communications by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you may opt out from such communications by emailing us at support@quarterspot.com.
How and When Your Information Is Shared With Other Parties
We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell, rent or otherwise distribute your personal information to third parties without your consent to do so. Information about investors is shared with other parties in the following ways:
  • At users’ control, optional and mandatory non-identifiable information about investors is shown on profiles available to the public. This information can be updated, and certain information can be removed or not supplied;
Information about borrowers is shared with other parties in the following ways:
  • At users’ control, optional and mandatory non-identifiable information about borrowers is shown on profiles available to the public. This information can be updated, and certain information can be removed or not supplied;
  • Non-identifiable business information relating to borrowers may appear on loan listings that may be viewable by qualifying investors; and
  • Credit and financial information relating to borrowers may be displayed on loan listing to qualified investors.
In certain situations, QuarterSpot may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose collected information to the extent we believe it necessary to comply with the law, to limit fraud or to defend a legal claim, such as in response to a subpoena or court order or similar legal process, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others. Additionally, we may transfer your information to successor in interest, which may include but may not be limited to a third-party in the event of an acquisition, sale, merger or bankruptcy. In these cases, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
QuarterSpot works with trusted providers who perform vital operational functions for QuarterSpot, including web hosting services, analytics providers, collection agencies, banks, credit bureaus, accountants, consultants, attorneys and payment service providers. Collected information may be shared with these third parties to the extent required for them to facilitate the offering of the Website and Services by QuarterSpot. These service providers are obligated to keep your information confidential and authorized to use your personal information only as necessary to provide these services to us.
Anonymization of Parties
Investors and buyers will be identified on the Website and Service by the screen names of their choice, which will be viewable to other users of the Website and Services. In addition, borrowers may have public profiles on the Website and Services that display loan listings along with information about them, including credit ratings and other provided financial information to permit the evaluation of the borrower’s loan requests. As identified, this data may also be included in anonymized form on statistical pages.
How Borrower Credit History and Loan Data Are Shared
When we create a loan listing for a loan on the Website or Service, we will be making information visible to investors on the site. This information may include data regarding your loan request, your screen name, geographic location, QuarterSpot rating and a description of your loan request.
Qualified investors using the Website or Services may see certain credit-related data we derive from a credit bureau. This information is made available to investors to permit them to evaluate your request for a loan. Your business credit profile and history on the Website and Service may include:
Your business credit profile and history on the Website and Service may include:
  • Commercial credit score range of the borrower;
  • Trade lines;
  • Delinquencies;
  • Bankruptcies;
  • Collections;
  • Tax liens;
  • Judgments;
  • Credit inquiries;
  • Length of credit history; and
  • Average number of days the Borrower pays its debts beyond their terms.
If you receive a loan through the Website or Service, we may display status information to investors about your loan. Your loans and activities on the Website and Services may be related to your borrower screen name on the Website or Services, so please select a name that will not disclose the identity of your business should you wish to remain anonymous.
Where You Can Find and/or Correct Your Information
Upon request QuarterSpot will provide you with information about whether we hold any of your personal information. If your personal or business information changes, you can access business-related and personal information collected online and maintained by the Website and Services by visiting the account section of the Website and Service. You will need the screen name and password to access this information. If you would like to change any information that you cannot modify directly, please contact us at support@quarterspot.com. If you no longer desire our Services, please contact us directly using the information below. We will respond to your request within 30 days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Web-related Information Collection
We also may collect information automatically about your visits to our Website and use of our Services, such as your IP address, Internet Service Provider (ISP), information about your computer and peripherals, referring website, geographical location, length of visit, browser type and page views (e.g. HTML pages, graphics, etc.), date/timestamp and/or clickstream data and store it in log files. We use this analytical information, in the operations, marketing and enhancement of our Website and Services. We do not link this automatically-collected data to personal information.
We use cookies to track affiliate deals and to store your passwords, so you don’t have to enter it more than once if you so choose. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.
Our partners/affiliates use persistent cookies to allow QuarterSpot to better service our customers with tailored advertising and site content. These cookies may be used to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here) Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Compliance with Laws
This policy may not discuss all of your privacy rights, as such rights vary depending on state law. Consult with your local agencies for more information.
Federal and State regulations may require us to maintain and report information regarding our users, investors or borrowers. We may be required to maintain your information for seven years or more in order to comply with applicable laws.
Links
Our Website or Service may contain links to other websites or may otherwise navigate you outside our Website or Service. We are not responsible for the privacy practices of such other sites, apps or other locations. When you leave our Website or Service, please read the privacy statements of your destination. This Privacy Policy applies solely to information collected by our Website or Service.
Some of our pages utilize framing techniques to serve content to from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to QuarterSpot.
Our Website may also include Social Media Features, such as the Facebook Like button and plug-ins, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.
Security Policy
Security is important at QuarterSpot. We therefore take steps to secure the information you provide through the Website or Service. Information we collect is protected internally by passwords and defined access points. Our systems are housed in secure facilities. Both physical and electronic access to our system is controlled by high-ranking managers. We store sensitive financial data such as Social Security numbers and bank accounts in a SAS 70 environment.
We utilize Secure Socket Layer (SSL) technology when you connect to our Website and Service and to encrypt data transfers. We also use a 128-bit secure browser for logins and transactions. Our Website and Service may make use of "CAPTCHA" technology. We may also use session time-outs for inactivity to protect your account.
When we communicate with you, we will only use the last four digits of your account numbers. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of your personal information, you can contact us at support@quarterspot.com.
We may employ password standards to assist you in selecting a secure password. This may require the use of both numbers and letters. We may also provide steps by which you can regain access to your account should you forget your password, including the use of a security question. We will never ask for your password as a means of identifying yourself. You should not share your password with anyone, and if you ever receive an email purporting to come from us that asks for your password, you should immediately contact us at support@quarterspot.com.
Contact Information
If you have any questions, comments, requests or suggestions regarding our Privacy Policy, please contact us at the information below:
QuarterSpot
Attn: Compliance Department
2751 Prosperity Ave. Suite 330
Fairfax, VA 22031
support@quarterspot.com
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