Privacy Policy

Updated July 10, 2024

This statement sets forth the Privacy Policy (“Policy”) of EquityBee Inc. and EquityBee Securities, LLC having their registered office address at 955 Alma Street, Palo Alto, CA 94301; EquityBee Fund Management LLC, having its registered office address at 221 25th St Ogden, UT 84401] and Equity Bee Technologies Ltd., having its registered office address at 13 Leonardo da Vinci Street, Tel Aviv, Israel, and affiliated companies (“we”, “us”, “EquityBee”). The Policy covers the topics below. If you have additional questions about privacy or information security, please contact us at: privacy@equitybee.com.

When you visit the Platform (as defined below), or use or interact with any of our Services (as defined below), we will collect information from or about you or your device, which may include personal data which will be handled as described in this Policy. For the purposes of this Policy, Personal Data shall mean any information relating to a natural person who can be identified by reference to such data, or as defined by applicable privacy laws. Personal data includes not only data from which one can identify a person directly, such as a person’s name, surname, personal identification number, but also other data, such as email address, phone number, IP address, birth date or other data, which can be used to identify a person indirectly.

EquityBee respects the privacy of its customers, vendors, platform visitors, and others, and is committed to protecting the Personal Data that they share with us. This Policy describes how EquityBee collects, uses, shares, secures and processes Personal Data in the course of providing its services through its website www.equitybee.com (the “Platform”), and outlines the ways in which our customers can control our use of that information.

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. You should review the Privacy Policy periodically to remain informed of any changes.

Please note: you are not obligated by law to provide us any Personal Data. However, without providing it you will not be able to receive the Services (as defined below) which require registration and provision of details as stated below.

By registering on our Platform and opting in to the terms of this Policy, or by using the Platform or services made available through the Platform (the “Services”), you thereby acknowledge this Policy. If you do not agree to be bound by this Policy, you should exit and cease all use of the Platform and Services. Providing your details when registering the Platform constitutes a declaration on your part regarding their correctness.

Note that those aspects of this Policy which are mandated by the EU General Data Protection Regulation (“GDPR”), in particular any rights (such as Data Subject rights detailed below) and duties conferred by GDPR, will apply only to the extent that GDPR applies to you.

Table of Contents

  1. General
  2. Types of Data Collected and How we Process Data
  3. Lawful bases for Personal Data processing
  4. Disclosure of Personal Data
  5. Transfer of data outside EEA
  6. Data storage and retention
  7. Information security
  8. Children
  9. Data subjects’ Rights
  10. Rights of EEA Data subjects
  11. Cookies
  12. Changes to this Policy
  13. Contact
  1. General
  2. EquityBee provides an investment platform, accessible from mobile and fixed devices, allowing option-holders of various companies to receive the funding required to exercise their options (and additional funding in certain circumstances) from investors and assisting such investors to execute such investments, under the terms of agreements executed by option-holders and investors with EquityBee (the option-holders and investors who have registered the Platform shall be referred to as the “Customers”).
  3. We may also collect Personal Data of a visitor to our Platform who interacts with our Services, including option-holders and investors who did not complete Platform registration (a “User”).
  4. In this context, EquityBee is the controller of Personal Data it collects and processes about Customers and Users. Such Personal Data collected shall be processed by EquityBee in accordance with this Policy.
  5. Types of Data Collected and How we Process Data
  6. Summary: we collect various categories of personal data in order to meet our contractual obligations, and also to meet various legitimate interests, such as fraud prevention and marketing.
  7. We may collect the following types of Personal Data:
  8. Data provided by you:
  9. Registration and Usage information required for option-holder customers registering on or using the Platform, that may include (without limitation) identification details, such as first and last name, phone number, physical address, e-mail address, spouse’s name, stock option information, information about your place of work and position, bank account, identification card and other documents submitted to comply with KYC (“know your customer”) requirements, information on transactions executed by employee through the Platform, username and password. We will also process financial information required under applicable law via our paying agent and we may use a video recording capturing employee consent to the EquityBee agreement.
  10. Registration and Usage information required for investor customers registering on or using the Platform, that may include (without limitation) first and last name, phone number, physical address, e-mail address, residency, investment experience and preference, accreditation information, bank account, identification card, occupation, employer, SSN, EIN, incorporation jurisdiction, incorporation documents for entities, annual income for the last 2 years (individual and household), net worth, CRD number (if applicable) and other documents submitted to comply with KYC (“know your customer”) requirements and information required under applicable law, information on transactions executed through the Platform by the investor, username and password.
  11. The username and password are used to ensure that only you have access to your account.
  12. In addition, we receive and store any information you voluntarily enter on our Platform or give us in any other way (for example, in the course of subscribing for particular investments as an investor, or other communications with us, or as contained in written documents you provide).
  13. Information you may provide when you communicate with us by phone, e-mail, or otherwise, or once you enter information on our Platform. We may monitor and record phone calls, e-mails, live chats, or other communications between you and our Service representatives or other representatives.
  14. You may provide information on behalf of another person or entity. If you completed the registration on behalf of another person or entity or if you otherwise provide information regarding another person or entity, you represent to us that you were authorized by that person or entity to give us consent to use the submitted information.
  15. Information Collected by Tracking Technology:
  16. When you visit our Platform or access our Services we use (and authorize third parties to use) pixels, cookies, events and other technologies (collectively, “Tracking Technologies”). Those allow us to automatically collect, store and analyze information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics and customize your experience. We store Tracking Technologies when you visit our Platform or access our Services. These are called “First Party Tracking Technologies”.
  17. In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners and advertisers) – these are called “Third Party Tracking Technologies”. Both types of Tracking Technologies may be stored either for the duration of your visit on our Platform or for repeat visits.
  18. We also collect behavior data of the User on our Platform, which includes keystrokes, recording of mouse movements and other activities on our Platform, and any information provided by Customers and Users at the time of using the Platform, posting material or requesting further Services as well as details of User’s use of the Platform and visits to the Platform including traffic data, location data, IP and log-in information, browser type, computer information, language, communication data, operating system, Internet Service Provider (ISP), time stamps, and the resources of User’s access from.
  19. We use a tool called “Google Analytics” to collect information about use of our Service. Google Analytics collects information such as how often Users visit our site, what pages they visit when they do so, and what other sites they used prior to visiting this site. We use the information we get from Google Analytics only to improve our services. Google Analytics collects only the IP address assigned to you on the date you visit our site, and plants a cookie on your web browser to identify you as a unique user the next time you visit. The cookie cannot be used by anyone but Google and we do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this site is detailed on the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser as described below.
  20. How to Manage Your Tracking Technologies Settings
  21. There are various ways in which you can manage and control your Tracking Technologies settings. Please remember that, by deleting or blocking Tracking Technologies, some of the features of the Services may not work properly or as effectively.
  22. Web browsers - Information about cookies is usually found in the “Help” section of the web browser. For more information, please refer to the “Cookie” section below.
  23. Mobile Devices - You can-opt out of certain types of interest-based advertising (or “cross-app” advertising), by accessing the “settings” on your device.
  24. Please note that the above information may change when manufacturers update their systems. Also note, that your device may use another platform, not described above. In that case, please consult the manufacturer documentation for further instructions.
  25. Collection of Personal Data from other sources
  26. We may also collect additional Personal Data about Customers and potential Customers such as place of work, position, job title, tenure - for the purpose of marketing to such employees; such data shall be collected from social media platforms, depending on such social media platforms and your privacy settings on them.
  27. Non-personal Data and site usage data
  28. We may also collect non-personal data which consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ on the Service and activities on the Service, the period of time the User visited the Service and related timestamps, etc. Non-personal information shall be gathered by us in order to examine the Users’ interactions with the Services and users activities and characteristics in order to operate the Service and improve it. For the avoidance of doubt, any non-personal data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
  29. Sensitive Personal Data: We do not intentionally collect sensitive Personal Data (for example, information revealing race, ethnic origin, political opinions, religion, etc.) and we ask our Users not to upload such information to the Platform.
  30. Lawful bases for Personal Data processing
  31. Summary: we process personal data to meet our contractual and other obligations, protect our rights, manage our business and provide our services.
  32. Personal information will be used by EquityBee – including also its affiliates' employees, consultants – in connection with the operation and management of the Platform and Services, to enhance performance of the Platform, to tailor the Platform to Customers’ preferences, to analyze trends and to protect us and our users including, without limitation, divided here based on the applicable lawful basis for the processing, as follows:
  33. Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; or on the basis of Consent:
  34. To provide the Customer with access to the Platform and use of the Services.
  35. To carry out our obligations arising from any contracts entered into between our Customer and us, including carrying out transactions which our Customers have requested, responding to User’s support requests and to User’s requests to execute data subject rights as detailed below.
  36. To enable us to verify your credentials, in order to maintain reasonable security.
  37. Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us, e.g. SMS messages, web notifications, e-mail, phone calls) of changes or updates to our Services, remind you of your obligations under your agreement/s with us etc. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use. This data may alternately be processed based on Your consent to such processing.
  38. Processing which is necessary for the purposes of the legitimate interests pursued by EquityBee or by a third party of providing an efficient and wide-ranging service to customers:
  39. To enable us to detect problems on our Platform, to develop and improve the features, contents and Services available, fulfill your requests for our Services, in connection with your use of the Platform or Services, to respond to your inquiries about our Services, to offer you our Services that we believe may be of interest to you.
  40. For analytics, statistical and research purposes, including providing our business partners and affiliates with aggregated statistical data.
  41. To notify Customers and Users about changes to our Services and provide information that is relevant to their use of the Platform.
  42. To protect and enforce our rights, privacy and security, safety, networks, systems and property, or those of other persons, and resolve disputes.
  43. Our Platform uses technologies to record your mouse clicks and activity on the Platform. The information collected does not include bank details or any sensitive personal data. The information collected is used to improve our Platform and Services usability, for performance monitoring, problem detection and to offer our Customers with customized offers in accordance to their preferences.
  44. Promotional and Marketing Communications: Subject to your approval, we may send you notifications, messages and other promotional updates about new features, unrelated offerings, events and special opportunities or any other information we think you may find valuable. We may provide such notices through any of the contact means available to us (e.g. SMS messages, web notifications, e-mail, phone calls etc.), through the Services, or through our marketing campaigns on any other site or platform, including social media platforms. You may opt-out of such communication in the registration process, or notify us at any time by sending an email to: unsubscribe@equitybee.com or by choosing to opt out of receiving additional promotional communications from us by clicking on the 'unsubscribe' link in any such message, or by following any instructions we may include in the message sent to you (the “Opt-out request”). Please note that, once we receive your request, it may take an additional period of time for the Opt-Out Request to become effective.
  45. Processing which is necessary for compliance with a legal obligation to which EquityBee is subject:
  46. For compliance with a legal obligation that applies to us or third party with whom we work (e.g., anti-money laundering regulation, to respond to a court order or a regulator).
  47. To provide reports (via our paying agents) that include user's Personal Data to tax and/or anti-money laundering authorities, or any other competent authority in Israel or elsewhere, as may be required with accordance to legal requirements.
  48. We may use non-personally identifying information that we collect to provide statistical information about users of the Platform or Services, to improve the quality, design and content of our Platform, to analyze the use of our Platform and to cooperate with law enforcement.
  49. Disclosure of Personal Data
  50. Summary: we share personal data with our service providers, partners, and group companies, and authorities where required to provide the Services, meet our obligations, or for our Legitimate Interests.
  51. We may disclose Personal Data to third parties only in the following cases:
  52. Third-party vendors who provide services to us or facilitate or evaluate the Platform or Services, such as cloud storage providers, e-mail service providers sending e-mails on our behalf, third party analytics vendors which analyze the activities of visitors to the Platform, fraud prevention and data security providers;
  53. Our paying agent which transfers the investor’s funding to the relevant company and executes the transactions on our behalf in a liquidity event;
  54. Companies within our corporate family that are involved in operating or providing the Services. Such affiliates will follow practices that are substantively at least as restrictive as the practices described in this Policy;
  55. To comply with applicable laws and regulations, such as tax and anti-money laundering regulations, or to comply with competent authorities in Israel or elsewhere;
  56. If we are under a duty to disclose or share Personal Data in order to comply with any legal obligation, such as in response to a subpoena, including to law enforcement agencies and courts in Israel and other countries where we operate or in order to enforce or apply our Platform Terms and other agreements;
  57. Where needed to enforce our rights; when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company or our Platform, our Customers, staff or others; and in connection with our Terms and other agreements, including where we believe a counterparty may have breached the Terms or other agreements with EquityBee; to detect, prevent or otherwise address fraud or illegal behavior, security or technical issues, or as needed to support external auditing, compliance and corporate governance functions; and/or
  58. In the event that EquityBee goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Data may be among the assets transferred and it will be transferred subject to restrictions similar to those contained herein or as otherwise be required by applicable laws and regulations.
  59. Except where permitted as stated, EquityBee does not sell, rent, share or otherwise disclose Personal Data to third parties.
  60. Please note that we may also use and disclose information that is not personally identifiable.
  61. Transfer of EU/UK data outside EEA/UK
  62. Summary: we transfer personal data within and to the EEA, USA, Israel and elsewhere, with appropriate safeguards in place.
  63. As part of the Services offered to you through this Platform, the information which you provide to us will be transferred to countries outside the European Economic Area (“EEA”). For example, we use cloud storage and computing facilities based in the USA, EquityBee is based in Israel, and our parent company is based in the USA. The data protection and other laws of these countries may not be as comprehensive as those in your country. Transfers of Personal Data outside the EEA will be made in accordance with GDPR Chapter V. In particular, transfer to the U.S.A. will be undertaken on the basis of Standard Contractual Clauses (available here); transfers from EquityBee to Israel will be undertaken based on the EU Commission’s adequacy ruling (available here).
  64. Data storage and retention
  65. Summary: we retain personal data according to our data retention policy, as required to meet our obligations, protect our rights, and manage our business.
  66. Our data retention policy is available to our customers on request. Data of website visitors, non-Customers and other data subjects is retained for the duration of the use of the data and a short period thereafter determined bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at a reasonable time. In addition, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations.
  67. Information security
  68. Summary: we take data security very seriously, invest in security systems, and train our staff. In the event of a breach, we will notify the right people as required by law.
  69. We employ various technical and administrative measures to protect and maintain the security, integrity, and availability of your data, as applicable.
  70. Your data is stored on secure servers and we limit access to it on a “need to know” basis, in order to enable the carrying out of the agreement between us.
    While we seek to protect your data to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet.
  71. Children
  72. We do not knowingly collect or otherwise process Personal Data from children under the age of 16. Please inform us if you believe we may be doing so in error, in which case we will, where possible, delete such data or otherwise ensure its lawful processing by EquityBee.
  73. Data subjects’ rights
  74. Subject to applicable laws, you may have certain rights regarding your Personal Data, such as the right to access the Personal Data held about you, or to make any necessary changes to ensure it is accurate and up to date. To exercise your applicable rights, send an email to privacy@equitybee.com. Data subjects’ rights are not absolute and are subject to applicable legal restrictions. To exercise these rights, you may be required to provide identifying data.
  75. Rights of EEA data subjects
  76. Summary: depending on the law that applies to your personal data, you may have various data subject rights, such as rights to access, erase, and correct personal data, and information rights. We will respect any lawful request to exercise those rights.
  77. Where GDPR applies, data subjects may exercise various rights over their personal data. These rights may include the following, depending on the circumstances: right to access your Personal Data kept by the EquityBee, right to rectification of any inaccurate Personal Data, right to erasure of your Personal Data, the right to object or restrict the processing of your Personal Data, and the right to data portability. You may lodge a complaint with the competent data protection authority regarding the processing of your personal information.
    However, please note that these rights are not absolute, and may be subject to our own legitimate interests, conflicting rights, and regulatory requirements.
  78. To protect the privacy and the security of your information, we may request information from you to enable us to confirm your identity. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the Personal Data that we maintain.
  79. You may contact us in order to exercise your rights by sending an email to privacy@equitybee.com. We will respond to your request in a reasonable timeframe, with accordance to applicable law.
  80. Cookies
  81. Summary: with your consent, we place cookies on your device. You control our use of cookies through your device and browser.
  82. When you access or use our Platform or websites, EquityBee may use industry standard technologies such as cookies, pixels and similar technologies, which store certain information on your computer or browsing device and which will allow us to identify the computer or device and, in some cases, to identify them with the user, and to enable automatic activation of certain features, and make your user experience more convenient and effortless. We use different types of cookies: some cookies are strictly necessary, they are required for the operation of our websites and Services under our terms with you; We also use analytical and performance monitoring cookies, which allow us to recognize and count the number of visitors and to see how visitors move around our websites and services when they are using it. Finally, we use functionality cookies which are used to recognize you when you return to our Site. This enables us to personalize content to your preferences, including for example, your choice of language or region.
  83. Different cookies are kept for different periods. Session cookies are used to keep track of your activities online in a given browsing session; these cookies generally expire when the browser is closed but may be retained for a period on your device. Permanent cookies remain in operation even when you have closed the browser; they are used to remember your login details and password. Third-party cookies are installed by third parties with the aim of collecting certain information to research behavior, demographics. Third party cookies on our site include, for example, Google Analytics. Likewise, pixels from Facebook and others enable integration of third party service providers (e.g., Twitter, Youtube, Pinterest, Instagram) may be embedded on our site. Third party cookies will be retained according to the terms of those third parties, and you can control those cookies in your browser settings.
  84. We use cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests of improving, optimizing and personalizing our services, and these are not overridden by your rights.
  85. You can allow or block cookies saved by websites on most browsers. How you can do this will depend on the browser you use. Further details on how to disable cookies can be found here: Microsoft Edge, Google Chrome, Firefox, Safari.
  86. Note: If you don't allow sites to save cookies, most sites that require you to sign in won't work.
  87. You can block or allow all cookies by default.
  88. EquityBee does not share personal data (phone numbers) and consent with third parties / affiliates or partner
  89. Changes to this Policy
  90. From time to time, we may update or amend this Policy to reflect new or different privacy practices. You should review the Privacy Policy periodically to remain informed of any changes.
  91. Additionally, if the changes will materially affect the way we use or disclose previously collected Personal Data, we will notify our Customers about the change by sending a notice to the primary email address associated with the Customer. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the terms of the updated Privacy Policy.
  92. Contact
  93. Customers, Users, data protection authorities can direct all queries to our privacy team at: privacy@equitybee.com. Our article 27 GDPR EU Representative is MyEDPO Limited, available at info@myedpo.com.

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