Updated October 5, 2017
Christina collects personal and financial information from you when you visit the Site. The majority of information is collected during the registration and/or application process and, while some items are optional, most are required for legal or security purposes. You may choose to provide additional information during subsequent visits to the Site, but keep in mind that some of this information will be required if you wish to partake in the services that we provide (“Services”).
In general, the type of information we collect includes, but is not limited to:
Personal data required to verify your identity;
Personal and financial data necessary to assess your eligibility to utilize the Services on the Christina platform; and
un-identifiable and aggregated personal data pertaining to your Site visits that help us maintain the appropriate features, functionality and user experience
Investor registration will require you to provide basic personal data. Such information typically includes your name, email address, home address and phone number, date of birth, social security number and/or tax identification number, employer and job title. Christina uses this data to: (i) enable you to log in to the Site; (ii) establish your ability to view offering materials and to make investments through the Site (for U.S. residents, such ability is restricted to “accredited investors” with a certain level of annual income or net worth); (iii) verify that you are at least 18 years of age; (iv) guard against potential fraud; (v) contact you if there is a problem with your account; and (vi) maintain regular communications with you as may be necessary to inform you of upcoming investment opportunities and other company updates.
Christina will also gather the names and email addresses of users who contact us through the Site with questions about our company. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested to do so.
When you subscribe to make an investment in one of the offerings on the Site, you will again be asked for your personal data. You will also be required to provide financial data, such as your bank routing number and bank account number, to enable us or issuers to utilize your bank account to originate funds transfers and make subsequent investment disbursements to you.
Christina or our service providers may also collect web surfing data related to your use of the Site. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Site. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. Christina may, for example, use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies, and other marketing activities. We also use it to help optimize the Site based on the needs of our users.
Christina does not sell, trade or license personal information about its users for marketing purposes. We do, however, work with a number of trusted partners who perform vital functions as part of our operations.
We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing, reporting, tax documentation, electronic payment, electronic signature, custody or escrow services. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your information private and secure.
We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or our services, or to protect the rights, property or personal safety of Christina, its users, issuers, or others.
Christina will send you email notifications from time to time. Some notifications are required elements of your transactions on our platform, such as confirmations of particular actions you have taken. These mandatory notices are sent typically to notify you of a change in status. For example, you will receive a notice when you are confirmed as an investor.
We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that another person cannot make a change to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or Site policies. Generally, you may not opt out of such service-related emails.
When you register as an investor, you will receive emails that confirm specific actions you requested. These will include emails to which you must respond to complete your registration and notifications confirming your registration. Thereafter, you will receive emails when a new investment opportunity is offered, as well as updates concerning the progress of the funding of such offering and/or other relevant information. If you make an investment through the Site, Christina will also send you confirmations of the investment as well as occasional updates as to the status of that investment and the timing of distributions relating to that investment.
We may also send you responses to emails you send us, if appropriate. From time to time, we will also send user surveys, requests for user feedback regarding user experience and Site operations, or marketing offers from us or from us on behalf of our marketing partners. Completing these surveys, answering requests for feedback, or accepting any offer is strictly voluntary. If you do not wish to receive these surveys, user feedback emails, and/or marketing offers, please opt out in any offer email you receive from us.
Although this Site is intended solely for users within the United States, it may be accessed by users located outside the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States, and that by providing your personal information on or through the Site then you consent to that transfer.
We limit access to the personal information we have about you to those employees who have a legitimate business need to access such information. We take commercially reasonable steps to protect against unauthorized disclosure or loss of your personal information. However, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, while we strive to protect user information we cannot ensure or warrant the security of any information you transmit to us or from the Site. You engage in such transmissions at your risk.
Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Site. Generally, identification and authentication take place through the use of your username and a password and/or while logging in with one of our technical support staff.
This Site is restricted to the use of adults over the age of 18. No portion of the Site is directed to children under the age of 13. Consequently, we do not collect personal identifying information from any person we know is a child under the age of 13.
Although some browsers currently offer a “do not track (‘DNT’) option,” no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers’ DNT signals.
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California customer, a business may be required to provide information regarding how that business has shared personal information of customers with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that do not disclose personal information to third parties for direct marketing purposes.