Privacy Policy

1. Information We Collect

Depending on how you use PrivPlce, we may collect information you provide directly to the platform, including:

• Account and identity information, such as your name, email address, username, telephone number, address, company or business information, and account credentials.
• Professional and profile information, including roles, licenses, languages, professional affiliations, attorney information, and other information you choose or are required to provide.
• Membership and invitation information, including invitations, confirmations, approvals, membership status, and related records.
• Identity, due-diligence, KYC, and compliance information that may be requested in connection with membership or a particular transaction.
• Transaction information, including opportunities, wanted requests, transaction terms, interests, matches, counterparties, procedures, status updates, and transaction history.
• Documents uploaded or generated in connection with a transaction, which may include identification documents, corporate documents, letters, agreements, banking-related documents, proof-of-funds or asset documentation, and other transaction materials.
• Communications and activity occurring through PrivPlce, including messages, comments, acknowledgments, approvals, document-sharing events, and other platform activity.
• Relationship and transaction-chain information, including intermediary relationships, referrals, introductions, transaction roles, and other records used to preserve the history and integrity of a transaction.

2. Information Collected Automatically

When you use PrivPlce, certain technical and security information may be collected automatically. This may include IP address, browser or device information, login activity, timestamps, security events, and records of actions taken within the platform.

PrivPlce may use cookies, sessions, or similar technologies that are necessary to operate authentication, security, preferences, and other platform functions.

3. How We Use Information

We may use information collected through PrivPlce to:

• Provide, operate, secure, and improve the platform.
• Create and administer accounts and membership access.
• Facilitate transaction discovery, matching, introductions, permissions, and workflows.
• Maintain transaction records, audit trails, document history, and relationship genealogy.
• Apply member-controlled visibility and information-sharing permissions.
• Communicate with members about accounts, transactions, security, platform activity, and administrative matters.
• Detect or investigate suspected fraud, misuse, false documents, unauthorized access, or other activity that may threaten members or the platform.
• Support legal, regulatory, compliance, accounting, and recordkeeping obligations where applicable.

4. How Information May Be Shared

PrivPlce is designed around controlled disclosure. Information is not intended to become publicly available merely because it is entered into the platform.

Information may be shared with other PrivPlce members when you authorize or initiate that sharing, when platform permissions make the information available as part of a transaction workflow, or when disclosure is necessary to facilitate a requested connection or transaction.

Different information may become visible at different stages of a transaction. For example, an opportunity may initially be presented without revealing the identity of a seller or other sensitive information, with additional information made available only as the relationship and transaction progress.

PrivPlce may also disclose information to service providers that assist in operating the platform, or when reasonably necessary to comply with law, legal process, protect rights or safety, investigate misuse, or enforce platform agreements.

PrivPlce does not intend to sell members' personal information as a data-brokerage business.

5. Transaction Documents and Confidential Information

Members may upload or exchange highly confidential transaction information. You should upload or share information only when you are authorized to do so and when it is appropriate for the applicable transaction.

PrivPlce may maintain records showing when documents or information were uploaded, accessed, shared, acknowledged, or associated with a member or transaction. Documents may also include identifying or tracking information intended to protect relationships and create an audit trail.

Platform privacy controls do not replace any confidentiality, nondisclosure, contractual, professional, or legal obligations that may apply between members or counterparties.

6. KYC, Compliance, and Sensitive Information

Certain transactions may require identity verification, KYC, AML, eligibility, accreditation, licensing, or other due-diligence information. The information required may vary depending on the transaction, participants, jurisdiction, and applicable requirements.

Providing information to PrivPlce does not by itself constitute regulatory approval, certification, verification, or a determination that a member or transaction satisfies applicable legal requirements.

7. Security

PrivPlce uses administrative, technical, and organizational measures intended to protect information and restrict unauthorized access. These measures may include access controls, authentication safeguards, activity logging, controlled document access, and other security practices.

No online system or method of electronic storage can guarantee absolute security. Members are responsible for protecting their login credentials and for promptly reporting suspected unauthorized access.

8. Data Retention and Transaction History

PrivPlce may retain account, transaction, communication, document, audit, security, and compliance records for as long as reasonably necessary to operate the platform, preserve transaction history and relationship records, resolve disputes, enforce agreements, meet legitimate business needs, or satisfy applicable legal and regulatory requirements.

Because PrivPlce is designed to maintain transaction history and auditability, closing an account or ending participation in a transaction may not result in deletion of all historical records associated with that account or transaction.

9. Your Choices and Responsibilities

Where available, members may manage profile information, transaction visibility, Private Network permissions, and other sharing preferences through their account. Certain information may be required to maintain membership or participate in particular transactions.

Members are responsible for ensuring that information they submit is accurate and that they have the right and authority to provide, upload, or share it.

10. Third-Party Services and Counterparties

PrivPlce may facilitate introductions or interactions involving independent members, counterparties, financial institutions, professional advisers, service providers, or other third parties. Their handling of information may be governed by their own agreements, policies, professional duties, or legal obligations.

PrivPlce is not responsible for the independent privacy practices of third parties once information has been lawfully disclosed to them outside the platform's control.

11. International Use

Private transactions may involve participants in different countries. As a result, information may be accessed, processed, or transferred across jurisdictions where permitted and appropriate. Members are responsible for complying with requirements applicable to information they provide or share in connection with their activities.

12. Changes to This Policy

PrivPlce may update this Privacy Policy as the platform, its features, or applicable requirements evolve. The current version will be identified by the “Last updated” date shown above. Where appropriate, material changes may also be communicated to members through the platform or other available contact methods.

13. Contact

Questions or requests concerning this Privacy Policy or the handling of information through PrivPlce may be submitted through the contact method provided by PrivPlce.