The technology platform at TycoonInvest.com (the “Site”) is owned by Tycoon Venture Partners Inc. and licensed to TycoonoInvest Portal LLC, a wholly-owned subsidiary (together, “TycoonInvest”, “we,” “us,” “our” or the “Company”). Under “Collection of Information” below, we collect information from users (“you”, “your”, or “User”) in various ways when you interact with our Site. By using our Site, you consent to our collection and use of information as explained in this Privacy Notice and agree to be bound by our Terms of Use. If you choose to invest in an offering that is advertised on our Site, you will be required to agree to a separate agreement, including, but not limited to, new or additional privacy notices or terms of use.

Collection of Information

TycoonInvest collects non-personally identifiable information from you regarding your usage of our Site (“Non-Personally Identifiable Information”). Information that is Non-Personally Identifiable could include, without limitation, Site pages viewed, websites visited before visiting the Site, frequency of visits, clickstream data, browser type, operating system, organization name, internet connection speed, presentations, and videos viewed, time spent viewing pages of our Site or using certain features of our Site, demographic data, cookies existing on your computer, search criteria used and results, date and time of access or visits to our Site, frequency of visits to our Site, and other information which does not specifically identify you. In the information collection process, we may use various technologies (some of which are described below), including, but not limited to, cookies, web beacons, web session variables, server log files, clear gifs, browser plug-ins or add-ons, or JavaScript. “Cookies” are pieces of information that may be placed on your computer by a site for the purpose of facilitating and enhancing your communication and interaction with that site. We use cookies to personalize content and ads, provide social media features, and analyze our traffic. We also share information about your use of our Site with our social media, advertising, and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. You consent to our cookies if you continue to use our Site. A “web beacon” may consist of a translucent graphic image (usually 1-pixel x 1-pixel) that is placed on a website or in an email that allows a website to record the simple actions of the User opening the page containing the beacon. A “Server log” can be construed as a single log file or several log files bundled and automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.

TycoonInvest also collects personal information from you (“Personally Identifiable Information”) when you sign up for an account, send us an email through the Site, sign up for a service through the Site, or make an investment through the Site. Personally Identifiable Information refers to non-public information that personally relates to or identifies you (such as your name, password, age, date of birth, gender, email address, postal mailing address, home/mobile telephone number, and/or taxpayer-identification number, Internet protocol (“IP”) address, investment objectives or experience, assets, income, and other comparable information, or other information you provide or upload to the Site such as photographs, replies, and answers to surveys or questionnaires, or responses completed on blank fill-in forms) made available to you on the Site. We request that you provide us with personal information, including, but not limited to, your personal or company social media profile, demographic information, financial information about issuers (i.e. valuations, share prices, fundraising goals), financial information about individuals (i.e. net worth) and other information requested from time to time. The collection and storage of your information may also include non-Personally Identifiable Information or Personally Identifiable Information, locally on your computer or device using instruments such as browser web storage or application data caches. However, not all non-Personally Identifiable Information and Personally Identifiable Information is stored.

Analytics programs and/or service providers, such as Google Analytics, which can use third-party cookies to report on your interactions with the Site may also be used. Such analytics programs collect information including, but not limited to, the time of each of your visits to the Site, whether you have visited the Site before, what website referred you to the Site, and what pages you viewed on the Site.

This Privacy Policy does not cover the collection of information by cookies or other methods by Third-party Services (as defined below) or other third parties, such as our business partners. The process in which these Third-Party Services or third parties collect information or by what means such Third-Party Services or third parties may use their own cookies to collect information about you is out of our control.

Use of Information

Consistent with this Privacy Notice, TycoonInvest may use the information you provide. Non-Personally Identifiable Information or Personally Identifiable Information you provide may also be used by TycoonInvest to better serve you and enhance your experience with the Site, among other things. The use of this information may include having to modify or copy such Non-Personally Identifiable Information or Personally Identifiable Information, or other information such as images or textual content you provide, in order to give you a seamless and enjoyable experience.

As such, you consent to our use and disclosure of any information submitted to us via the Site, or information collected when you access the Site in any manner, and you acknowledge, agree, and accept that you have no expectation of privacy, confidentiality, or privilege in such information.

TycoonInvest may use Non-Personally Identifiable Information and Personally Identifiable Information: (1) to market our products and services to you; (2) to provide services and products requested by you; (3) to serve advertisements and marketing on our Site; (4) to allow vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of our Site and other services; (5) to analyze actionable data in order to send more targeted messages to you or other Users of our Site; (6) to conduct research and analyze data to improve our products, services, and Site; (7) to transmit and deliver email messages such as special offers, updates, newsletters, customer service, and service announcements; (8) to verify User information; (9) to comply with and meet regulatory requirements for the offer or sale of securities required by law, rules or regulations to our affiliates or members; (10) to protect our Site or its Users; (11) to engage in any and all lawful activities we believe are consistent with the foregoing; and (12) to protect against legal liability, when required by law. It is possible that we may provide any or all of these services through third parties, which may necessitate sharing Non-Personally Identifiable Information or Personally Identifiable Information with them.

TycoonInvest may make your information, including Non-Personally Identifiable Information or Personally Identifiable Information, available on its Site and visible to other Users of or visitors to the Site. For example, subject to certain preferences and permissions of your visibility on the Site, information you provide about yourself in response to questionnaires on the Site may be made available to others, such as information concerning your status as an accredited investor. As such, it may be possible for other Users of our Site to personally identify you based on the information you made available on our Site. Furthermore, if you utilize Third-Party Services to log into our Site, other Users to whom you may be connected through such Third-Party Services may be able to view information about you, including any Non-Personally Identifiable Information and/or Personally Identifiable Information on our Site.

TycoonInvest may employ or contract other third parties, companies, or individuals to perform certain functions or services on its behalf. Examples of these services from such third parties, companies, or individuals, may include ID verification (including, without limitation, facial images from ID or passport), electronic document signing, payment storing and processing, sending an email or postal mail, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service. As such, these third parties, companies, or individuals may have access to your information, including Non-Personally Identifiable Information or Personally Identifiable Information, needed to perform their functions or services, and may not use it for other purposes. TycoonInvest may also use and disclose Personally Identifiable Information and Non-Personally Identifiable Information to help us to carry out certain internal functions such as information management, account processing, client services, or other data collection relevant to our business; to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our Site or network; to protect and defend our rights or property or the rights or property of others; as required by administrative agencies or courts; and in connection with a sale, merger, reorganization, or financing of TycoonInvest’s business or assets. Any successor’s interest in our business would acquire the information we maintain, including Personally Identifiable Information, and may alter the terms of this Privacy Notice.

Except as identified here and subject to the user’s ability to opt-out as provided by Regulation S-P, TycoonInvest does not and will not sell any of your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to any third-party for purposes of soliciting, telemarketing, or marketing. TycoonInvest may provide Personally Identifiable Information, including your name, email address, and the date and company of any investment to certain third parties that have referred issuers and investors to TycoonInvest, or to certain Issuers, including but not limited to issuers in which you have expressed interest. TycoonInvest may also be required to disclose your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to other companies or entities in the event that TycoonInvest is sold to another company or entity. In which case, your information, including Non-Personally Identifiable Information or Personally Identifiable Information, could be sold or transferred to the acquiring company or entity.

Third-party Sites and Services

The Site contains links to other websites and services not maintained by TycoonInvest. In addition, other services and websites may link to or reference the Site. We encourage you to be mindful when you enter or leave our Site. You should also read the privacy statements of each website and service that you visit. We are not responsible for the privacy practices or the content of, other websites or services. We also do not endorse, screen, or approve the privacy practices or the content of, other websites or services.

Messaging

The Site allows Users to communicate with companies or issuers and other Users posting information on the Site. We may moderate such information by reading, collecting, and analyzing information transmitted between Users for regulatory compliance and marketing purposes. We do not guarantee that information provided by Site visitors or investors is accurate or complete. TycoonInvest assumes no liability or responsibility for any errors or omissions in the content of its Site.

Opt-out Policy

We may at times send you email communications with information, marketing, or promotional materials. If you prefer not to receive such emails from us, you may unsubscribe completely by selecting “unsubscribe” at the bottom of the emails you receive.

Opt-out requests may take up to five (5) business days to process. However, we may occasionally need to send you email communications that are transactional in nature, such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of.

You will have the ability to modify the information concerning your account by visiting your profile and settings page and editing the information you wish to change. Some of these modifications or edits may include, changing your email address, password, financial information, contact information, or other login information, subject to our Site policy. If you wish to suspend your account or need help modifying account information, please contact us at compliance@tycooninvest.com. We may require up to five business days to process such requests.

Access to the setting of certain permissions and preferences will be available through your account settings. Some of these settings may include, the visibility of your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to others. You may stop or restrict the placement of TycoonInvest’s cookies, Google’s cookies, and third-party cookies on your computer by adjusting your web browser preferences or a “Do Not Track” setting in your web browser. In doing so, you may still use our Site, but the restriction of these cookies may interfere with some of the Site’s functionality. You may also clear cookies from your computer via your web browser settings.

It is not our responsibility to remove your Personally Identifiable Information from the lists of any Third-Party Services or Providers who have previously been provided your information in accordance with this Privacy Notice.

Security

We make reasonable efforts to secure access to Personally Identifiable Information in our possession. However, we will not be held liable for any failure to safeguard such information, whether inadvertent or otherwise. Personally Identifiable Information is also stored with third parties who have informed us that they also use reasonable efforts to secure access to Personally Identifiable Information, but we will not be held liable for the failure of any third party to safeguard Personally Identifiable Information, whether inadvertent or otherwise.

To protect the transmission of your information on the Site, we use Secure Sockets Layer (SSL) software, which encrypts the information you input. Wherever appropriate, we obfuscate and/or encrypt information in our systems and/or during information transfer.

We utilize third-party service providers that may store addresses, financial information, electronic signatures, and payment information on their servers. Any third parties to whom we may disclose personal information may have their own privacy policies that describe how they use and disclose personal information. Those third-party policies will govern the use, handling, and disclosure of your personal information once in their possession, as described in this Privacy Policy. To learn more about the privacy practices of these third parties, we encourage you to visit their respective websites.

The protection of your User information, password, and computer against unauthorized access is of the utmost importance. You should log off whenever you have finished using a shared computer or other devices.

Children’s Privacy Policy

The Site is not intended for use by children. Anyone under the age of eighteen years old is prohibited from using the Site in any way, including providing personally identifiable information or receiving our email distributions. Under no circumstances do we knowingly solicit or collect Personally Identifiable Information from children under the age of thirteen (13) or anyone under eighteen years of age. If you believe that a minor has disclosed Personally Identifiable Information to TycoonInvest, please report this to us immediately by contacting us at compliance@tycooninvest.com.

Changes to This Privacy Notice

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Notice at any time. Any and all changes or updates will be effective immediately upon posting to our Site. We encourage you to review this Privacy Notice regularly for changes and to determine if changes have been made by checking the Effective Date below. Your continued use of our Site, subsequent to the posting of any changes to this Privacy Notice means you accept such changes.

Applicable Law and Jurisdiction

The Site is maintained in the United States of America. By accessing the Site, you authorize and consent to the export of Personally Identifiable Information to the United States of America, as well as its storage and use, as specified in this Privacy Notice.

This Privacy Notice shall be governed by, construed, and entered in accordance with the laws of the Commonwealth of Massachusetts applicable to contracts deemed to be made within such state, without regard to the choice of law or the conflict of law provisions thereof. All disputes with respect to this Privacy Notice shall be brought and heard within the Commonwealth of Massachusetts. You consent to the in-person jurisdiction and venue of such courts. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION, OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

UPDATED April 27, 2022