Privacy and Security Policy

At Lighter Capital, Inc. (the “Company”), your privacy is very important to us. The purpose of this privacy policy (this “Policy”) is to provide you with a description of the types of information we collect about you and your company when you visit the Lighter Capital web site located at www.lightercapital.com, and associated sub-domains (the “Site”), and how we use that information. By visiting or using the Site you agree to the provisions of our  Terms of Use  and this Policy. If you do not agree to the terms of this Policy, please do not use or access the Site or use the Services (defined below).

This Policy only applies to information collected while you are on the Site. For more information on how the Site may redirect you to other web sites, please see the “Links and Redirection to Third Party Sites” section below.

Information We Collect

We collect and store information that you voluntarily provide to us as well as data related to your Site visit.

In some areas of the Site, we request or may request that you provide personally identifiable information, including your name, address, email address, telephone number, and other information from which your identity is or may be discernible. We collect personally identifiable information from our users at several different points on the Site. We will also allow you the opportunity to provide information identifying the amount of funding you will be seeking, your company’s financial performance, and the intended use of funds. Such information is collected for the purpose of contacting you with information regarding prospective funding opportunities based on your specified interests (the “Services”). It is solely up to you whether you furnish such information. If you do provide such information, you are thereby consenting to the use of that information in accordance with the policies and practices described in this Policy. This information may be stored on our servers, and on the servers of third party service providers.

In addition, during your visit we automatically collect certain aggregate information and analytical data related to your Site visit (see “Use of Cookies” below). Aggregate information is non-personally identifiable or anonymous information about you, including the date and time of your visit, the IP address of your computer or mobile device, your computer or mobile device browser information, the Internet address that you visited prior to and after reaching the Site, the name of the domain and host you used to access the Internet, the type of mobile device you use, your mobile device’s unique device ID and the features of our Site which you accessed. This data is in no way associated with your personally identifiable information.

Most pieces of information we collect from our clients are collected once. Some pieces of information are collected on an ongoing basis, with our clients’ permission. For example, a client may provide us with read-only access to cash collections data, or sales growth data, on an ongoing basis. Such ongoing information is used to revise or continuously update a client’s financing application; we might say “no” one day, but based upon a longer history of ongoing information, say “yes” three months later. Clients may revoke their permission for any or all ongoing information collection at any time.

Clear Gifs (Web Beacons)

Our Site employs a software technology called clear gifs (a.k.a. Web Beacons), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may tie the information gathered by clear gifs to our clients’ personally identifiable information.

Analytics/ Log Files

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole.

We do link some of this automatically-collected data to personally identifiable information. This allows us to deliver a better experience by reducing the amount of data that needs to be entered when filling out forms, downloading gated content, completing surveys, etc.

How We Use Information

Lighter Capital’s mission is to help growing businesses (“you,” or “our clients”) get financing. The main way in which we do that is by investing our own money (we are a non-bank, private equity capitalized, investor). Any and all information we can collect about a client applying for financing, we will use internally to get the whole picture and to try and make the best investment decision for ourselves and for the client. This internal use includes sharing information among our employees, contractors, attorneys, capital providers (investors & lenders), and our Investment Committee. We will also retain and use this information to try and improve our decisions and our clients’ experience.

We use collected information to make available and to improve our high standard of reliable services. We use such information to:

·          respond to inquiries or service requests and monitor such responses;

·          provide information about and market our Services;

·          resolve problems; and

·          manage the Site and assess its usage and usage of the Services.

Security Section

When we solicit or accept confidential information over the Web, we will do it over a secure connection, which uses SSL encryption (of the same type used by banks, credit card companies, and major online retailers). To ensure that you’re on our secure site, please check that your browser shows a “locked” icon and that the web address you’re using starts with “https://”.

Our secure site is served from a locked data center environment, in a locked cabinet, and sits behind hardware and software firewalls. The confidential information it receives is, in turn, transmitted in encrypted form, on a physically separate network, and stored on physically isolated computers not directly connected to the Internet.

One option in our application process is to provide us with read-only access to bank accounts, in order to verify clients’ financial information. This requires bank account credentials to pass through our encrypted, secure site. When we receive such credentials, we treat them as “beyond confidential” and we do not store them in any way on our computers. Our only use of such credentials is to pass them to our technology partner, Finicity, Inc., via an encrypted, multi-factor authenticated connection, in a one-time transaction. The standard we measure our approach by is that even if our computers were physically seized, not a single set of bank credentials should be available to the attackers.

Within our organization, every employee or contractor is required to sign a non-disclosure agreement prior to accessing any client information. Only personnel with a legitimate need are given access to our information assets, and we use the principle of least privilege to help ensure that, should a breach occur, damage is minimized.

Email is, like FAX, post, and courier, inherently (being unencrypted) a less secure method of communication. We take measures to try and increase the security profile of such communications, including requiring the use of transport layer security (TLS) and/or SSL encryption for all internal access to @lightercapital.com email; however, we can’t control the security settings of an email message before in comes in to, or after it leaves, our email servers. Therefore, please do not send us confidential information via email unless you are comfortable with the security situation (and risks thereof) between your email outbox and our servers.

In the event we discover an unauthorized release of client confidential information, we will do our best to promptly inform those clients involved.

Disclosure of Information

We do not sell or rent personally identifiable information to anyone. Information that you provide will not be shared with any other user of the Site without your consent. We may disclose personally identifiable information to appropriate affiliates of the Company, including strategic alliance affiliates and third party service providers, to respond to a request for service or to provide information about available products or services. We are not limited in our use of non-personal information that does not permit direct association with any specific individual, or non-identifiable aggregate information about our users (such as the number of users of our Services, the geographic distribution of our users, the amount of information located and/or removed, etc.).

If you opt-in, we may share client information with external partners who can provide additional financing options. If we do this, we will screen which clients receive offers or contacts from which external partners, and try only to make matches of mutual benefit. Clients may revoke their permission for any or all external partner sharing at any time.

We disclose information that we, in good faith, believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our Terms of Use. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity’s contact information to victims who request it.

We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action. If the subpoena seeks information about an identified user or limited group of users, we’ll make reasonable business efforts to contact the user(s) before providing information to the party that requests it.  We cannot guarantee that we will be able to contact the user(s) in all cases, whether because of a time limit, court order, inability to effectively contact a user, or for any other reason.

We may disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).

We may share information with companies that partner with us to produce jointly sponsored content and events, such as webinars, so that they may contact you with related information about services you may be interested in. These third parties are obligated to protect your information and are prohibited from using your personally identifiable information for any other purpose.

We share information with companies that provide public relations and marketing services for us. Such information will only be shared by us to customize, measure and improve our products, Services and advertising; it will not be shared with third parties for their marketing purposes. These third parties are obligated to protect your information and are prohibited from using your personally identifiable information for any other purpose.

As with any other business, it is possible that in the future we could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by us, including client account information, but would continue to be bound by this Policy unless and until it is amended.

We may share aggregate (non-personally identifiable) information with certain third parties such as advertisers, national industry organizations, and prospective affiliates. In addition, we reserve the right to disclose aggregate information and personally identifiable information to third parties as required or permitted by law and when we believe that disclosure is necessary to protect our rights.

Unsubscribe Options

If you choose to take advantage of the Services by applying for financing, you will receive periodic emails regarding Services, based on the information you provide, may be of interest. If you no longer wish to receive our communications, you may unsubscribe by following the instructions included in each communication.

Use of Cookies

“Cookies” are simple text files stored on your computer for use by a browser. Certain Site features may only be available through the placement of a cookie. We may use “cookies” to assist in data collection and to track visitor Site usage and trends to help us better serve you. The use of cookies is a standard practice among Internet web sites; most Internet browsers permit a user to accept, decline or delete cookies. This Site works with a first party cookie that collects anonymous traffic data at the Site.

We use persistent cookies to make it easier for you to navigate the Site. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.

We set a persistent cookie to store how you came to the Site and what content you view. Persistent cookies also enable us to track and target the interests of our users to enhance their experience on the Site.

If you reject cookies, you will still be able to view the Site, but your ability to use some areas of the Site, such as automatically-generated recommendations, will be limited. You will be unable to apply for funding and log into the Site if you reject cookies.

Some of our business partners (e.g., analytical tracking software providers) use cookies and tracking technologies on the Site. We have no access to or control over these cookies or tracking technologies. This Policy covers the use of cookies on www.lightercapital.com and by us only and does not cover the use of cookies or tracking technologies by any such business partner.

Behavioral Targeting/ Re-Targeting

We may partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partners use cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests.

Updating Information

You may review, correct, update or change the personally identifiable information you provide at any time. If you would like to edit your personally identifiable information, please contact us for assistance at privacy@lightercapital.com.

Links and Redirection to Third Party Sites

The Site may contain links to third party web sites and may redirect you to third party web sites (“Third Party Sites”). These sites include, among others, service providers who have a relationship with the Company.

Third Party Sites are not under the control of the Company, and the Company is not responsible for such Third Party Sites, including without limitation the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness thereof, any link contained therein, or any changes or updates thereto. The inclusion or access to Third Party Sites does not imply an endorsement thereof by the Company, or of the provider of such content or services, or of any third party web site. The Company reserves the right to terminate any link or linking program at any time.

Please be aware that when you enter a third party web site, any information you provide, including financial information, is subject to the terms of use and privacy policy of that site.

Children’s Privacy

This Site and our Services are not directed to person under the age of 13. If you become aware that you child has provided us with personal information without your consent, please contact us at privacy@lightercapital.com. We do not knowingly collect or solicit information from, market to or accept services from children. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information and terminate the child’s account.

Effective Date; Policy Changes

Each time you use the Site, the current version of the Policy will apply. Accordingly, when you use the Site, you should check the date of this Policy (which appears at the top of the Policy) and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. Unless stated otherwise, our current Policy applies to all information that we have about you. We will not materially change our policies and practices to make them less protective of client information collected in the past without the consent of affected clients.

Lost or Stolen Information

You must promptly notify us if you become aware that any information provided by or submitted to the Site is lost, stolen, or used without permission.

Governing Law

This Policy is governed by the laws of the State of Washington, U.S.A. without giving effect to any principles of conflict of law.

Contact Us

To contact us with your questions or comments regarding this Policy or the information collection and dissemination practices of the Site, please contact us via email at privacy@lightercapital.com or by telephone at (206) 455-9633.

To see the Terms of Use that apply to the Site  click here .

All trademarks, service marks, and other proprietary materials herein are the property of Lighter Capital, Inc. 2016. All rights reserved.