Privacy Policy

We collect information that you provide, information collected automatically when you use the Services, and information from third parties.

Information you provide

• Account and identity data: name, email, phone number, date of birth, residential address, government-issued identification, and taxpayer identification numbers.
• Investor qualification data: accreditation status, source of funds, investment experience, and suitability information.
• Issuer data: entity information, beneficial ownership, authorized representatives, and offering materials.
• Financial and transaction data: bank or custody account details, wire instructions, subscription amounts, distributions, and transfer history.
• Communications: messages, support tickets, call notes, and feedback you submit to us.

Information collected automatically

• Device and usage data: IP address, browser type, operating system, device identifiers, pages viewed, referring URLs, and timestamps.
• Cookies and similar technologies: used to authenticate sessions, remember preferences, measure performance, and support security. See the "Cookies" section below.
• Log and security data: authentication events, audit trails, and fraud-prevention signals.

Information from third parties

We receive information from identity-verification providers, sanctions and politically-exposed-persons screening services, accredited-investor verification partners, banking and custody partners, analytics providers, and from your employer or the issuer when you are invited to the platform.

We use personal information to:

• provide, operate, secure, and improve the Services, including issuance, subscription, transfer, and reporting workflows;
• verify identity, perform Know-Your-Customer (KYC), Anti-Money-Laundering (AML), sanctions, and accreditation checks required by applicable law;
• facilitate communications between issuers, investors, and authorized representatives;
• monitor for fraud, abuse, and violations of our Terms of Service;
• comply with legal and regulatory obligations, respond to lawful requests, and enforce our rights; and
• send service, security, and transactional communications, and, where permitted, marketing communications you can opt out of.

Where the EU or UK General Data Protection Regulation applies, we process personal information under the following legal bases: performance of a contract with you, compliance with a legal obligation, our legitimate interests (including operating and securing the Services), and, where required, your consent.

We share personal information with:

• Issuers and their agents when you are an investor participating in an offering, and investors where you are an issuer or authorized representative;
• Service providers that perform functions on our behalf, such as hosting, analytics, identity verification, payment processing, email delivery, and customer support, bound by contractual confidentiality and security obligations;
• Regulators, law enforcement, and other authorities where required by law, court order, or to protect our or others' rights;
• Professional advisors including auditors, attorneys, and insurers, under confidentiality obligations; and
• Successors in connection with a merger, acquisition, financing, or sale of assets, subject to customary confidentiality terms.

We do not sell personal information.

Provium is based in the United States and may process personal information in the United States and other countries. Where required, we use appropriate safeguards such as the European Commission's Standard Contractual Clauses to protect cross-border transfers.

We retain personal information for as long as necessary to provide the Services, meet our legal and regulatory obligations (including books-and-records requirements applicable to securities activity, typically six years or longer), resolve disputes, and enforce our agreements. When no longer needed, we securely delete or anonymize the information.

We maintain administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest, access controls, logging, and regular security testing. No system is perfectly secure, and we cannot guarantee absolute security.

Depending on where you live, you may have rights to access, correct, delete, port, or restrict processing of your personal information, and to object to certain uses. Residents of California, Colorado, Connecticut, Virginia, Utah, and other jurisdictions with comparable laws have additional rights, including the right to opt out of certain types of processing and to appeal denials of rights requests. To exercise these rights, contact us at privacy@provium.io. We will verify your request consistent with applicable law.

You may opt out of marketing emails by following the unsubscribe instructions in those messages. Transactional and regulatory communications will continue while you are a user of the Services.

We use strictly-necessary cookies to operate the Services and, with your consent where required, analytics cookies to understand and improve performance. You can control cookies through your browser settings; blocking strictly-necessary cookies may prevent parts of the Services from functioning.

The Services are not directed to children under 18, and we do not knowingly collect personal information from them. If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to delete it.

We may update this Policy from time to time. If we make material changes, we will notify you by email or through the Services. The "Effective date" above indicates when this Policy was last revised.

Provium, Inc.
Attn: Privacy Office
Email: privacy@provium.io