Privacy Policy

INTRODUCTION

• Welcome to www.avenify.com (the “Avenify Site”), the Site of Avenify LLC (“Avenify” or “we”). The Avenify Site offers you the opportunity to fund your higher education by entering into income share agreements (“ISA’s”). This document (“this Privacy Notice”) describes how we collect, use, and share your PII on the Avenify Site.

• The Avenify Site is directed to residents of the United States who are seeking funding for higher education. It is not directed to, nor do we provide our services to, residents of the EEA.

• By providing the personally identifying information, which is defined below, and which is also referred to as “PII,” and other information that is described below on or through the Avenify Site, you expressly consent to Avenify’s collecting that information and to its using, storing, sharing and transferring that information as provided in this Privacy Notice. Please read this Privacy Notice carefully so you understand just what you are permitting us to do with your PII and other information that we collect when you use the Avenify Site.

• Further down in this Privacy Notice, you will see how you can contact us to manage, correct or delete your PII.

COLLECTION OF PII

• “Personally Identifying Information” is information that identifies you as an individual or relates to you as an identifiable individual. PII may include, but is not limited to, your first and last name, Social Security number, and home address. Under some privacy laws, PII may include online and device identifiers such as your IP address, usage data such as your browsing history (where you came from to get to the Avenify Site), protected classifications such as your gender or sexual orientation, and information about your personal preferences that may be collected through cookies and other tracking devices. This Privacy Notice refers to all such information as PII.

PII Collected on the Avenify Site

• If you apply for funding on the Avenify Site, we will collect certain PII from you, including your full legal name, email address, phone number, date of birth, and Social Security number.

• If you contact us to learn more about our services or choose to send us a message with information about yourself, we will collect the PII that identifies the source of that communication (for example, if you text us, we will collect your phone number) and we will maintain records of your correspondence that will include the email address and any other PII that you included in the email.

Other Information Collected through the Avenify Site

• We may automatically collect the following types of information as you use the Avenify Site. To read more about how we collect that information, see the section below on “Cookies and Other Tracking Technology.”

o Usage Information: We collect certain information automatically through your use of the Avenify Site, such as which of the pages on the Avenify Site that you access, the frequency of access, and what you click on while on the Avenify Site.

o Location Information: We may collect information about your actual location which may be determined from your IP address, GPS, and other sensors that may reveal information on nearby devices, Wi-Fi access points, and cell towers.

o Device Information: We may collect information about the device you are using to access the Avenify Site, such as hardware model, operating system, application version number, browser, and IP addresses.

o Mobile Device Information: In addition to the device information listed above, when you access the Avenify Site via a browser on your mobile device, we may collect mobile network information, including telephone number, the unique device identifier assigned to that device, mobile carrier, operating system, and other device attributes.

Information Collected through Cookies and Other Tracking Technology

Cookies

• What they are. A cookie is a small data file that a Site transfers to a user's hard drive when a user visits the Site. Cookies allow a Site or third party to recognize your browser. There are three primary types of cookies:

o Session cookies are specific to a particular visit and carry information as you view different pages within a Site. Session cookies expire and delete themselves automatically in a short period of time, e.g., when you leave the Site or when you close your browser.

o Persistent cookies enable us to recognize you when you visit the Avenify Site and remember your preferences. Persistent cookies are stored on your browser or mobile device until you choose to delete them, and otherwise typically delete themselves at expiration.

o Third-party cookies are placed by someone other than us. They may gather browsing activity across multiple Sites and sessions. They are usually persistent cookies and are stored until you delete them or until they expire based on the time period set in each third-party cookie.

• How you can control cookies

o You can set your browser to accept all cookies, to reject cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. Rejecting a cookie, however, may preclude you from using, or may negatively affect the display or function of, the Avenify Site or certain areas or features of the Avenify Site. To learn more about cookies, including how to enable cookies, change your browser settings and find and delete cookies on your hard drive, please refer to your web browser's help menus or visit www.allaboutcookies.org.

• How cookies are used on the Avenify Site

o Site analysis. We use Google® Analytics and other Service Providers (which term is defined below) to recognize and count the number of visitors to the Avenify Site and to see how visitors move around the Avenify Site when they’re using it. Cookies also allow us to provide you with customized content, keep track of preferences you specify while visiting the Avenify Site, conduct general analysis and research, and identify purchases that you make in response to our advertising.

 If you do not want your data collected with Google Analytics, you can install the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) running on Sites to prohibit sending information to Google Analytics. To opt out of Google Analytics, visit the Google Analytics opt-out page and install the add-on for your browser. For more details on installing and uninstalling the add-on, please see the relevant help resources for your specific browser. Updates to your browser or operating system may affect the functionality of the opt-out add-on. You can learn about managing add-ons for Chrome here.

o Interest-based advertising

 If you visit the Avenify Site as a result of a search on Google® or Yahoo® or another search engine, that search engine may serve you ads for other similar products and services when you are on other Sites with their networks.

 You can choose to limit this kind of behavioral advertising by Google by going to https://tools.google.com/dlpage/gaoptout and opting out of interest-based ads on Google. To opt out from a list of vendors in addition to Google, go to http://www.aboutads.info/choices/. After you opt out, you will still see advertisements when you are online, but the advertising may not be as relevant to your interests. If you change your computer, change your browser, or delete your cookies, you will need to renew your opt-out.

Web beacons

• We may also use an application known as a "web beacon." A web beacon is an electronic file that usually consists of a single-pixel image that is used in combination with a cookie or cookies. A web beacon can be placed on a web page or in an email to transmit information, which could include PII.

• We use Facebook® Pixel. If you are on the Avenify Site when the Facebook web beacon is running, and then we run a “like” campaign on Facebook when you are on Facebook, you will see a “Like us” ad for Avenify. To opt out from Facebook® tracking, log in to the Facebook site and go to Settings & Privacy > Settings > Ads > Ad Settings. Then choose the Not Allowed option under each category.

• We also may use web beacons to assist in tracking and analyzing advertising effectiveness, verify activity conducted on the Avenify Site, count and recognize site visitors, and personalize your experience on the Avenify Site.

“Do Not Track” Signals

• With some browsers, it is possible for a user to activate a “Do Not Track” signal, to indicate that the user does not want to be tracked across the Sites that the user visits.

• The Avenify Site does not respond to Do Not Track signals. In other words, if you have activated a Do Not Track signal in your own browser, the Avenify Site will not block tracking of your activity on the Avenify Site by Google, its affiliates, or anyone else.

USE OF INFORMATION COLLECTED ON THE AVENIFY SITE. We use PII and other information that we collect in the following ways:

• Determining eligibility. We use your PII and the other information you provide to determine whether you are eligible for ISA funding.

• Providing Services. We use your PII to provide you with ISA funding (if you are eligible) and to fulfill our contractual obligations to you in connection with such funding.

• Communication. We use PII to communicate with you about the Avenify Site or our services. We may also use your PII to send account updates or other communications regarding your account or to inform you of any changes to the Avenify Site or our services.

• Customer Support. We may use your PII to provide you with technical support or answer questions about the Avenify Site.

• Maintenance and Improvement. We use the information that we collect to analyze how our users interact with the Avenify Site in order to maintain and improve the Avenify Site (“Analytics”), diagnose any problems with the operation of the Avenify Site, and improve the user experience.

• Research. We may use information that we collect on the Avenify Site for research purposes, for example, to improve our underwriting model or update funding eligibility criteria. For example, we may aggregate information that is derived from your PII to calculate the percentage of students seeking funding or obtaining funding in a particular ZIP code.

SHARING OF INFORMATION COLLECTED ON THE AVENIFY SITE. We may share information, including PII, with third parties, as described below:

• Disclosure to Service Providers. To maintain and operate the Avenify Site and provide the Services, we work with various third-party service providers (“Service Providers"). Service Providers include companies that service the ISA’s by helping you make and meet payment arrangements (“Servicers”). Service Providers also include vendors and suppliers that provide us with technologies, services and/or content for the Avenify Site, updating the data in the Avenify Site, Analytics, advertising and marketing, and customer services. Service Providers’ access to your PII is limited to what is reasonably necessary to provide their services.

• Disclosure to Third-Party Purchasers of ISA’s. We may sell your ISA to a third party so that we may continue to generate funds to continue to offer our funding services.

• Disclosure to Affiliates. We may share information with a parent company, subsidiary, joint venture, or other companies under common control with us.

• Disclosure for legal reasons

o We may disclose your PII to protect the safety, rights, or property of the public, any person, or Avenify; to investigate, prevent, or otherwise address suspected fraud, harassment or other violations of any law, rule or regulation; to detect, prevent or otherwise address security or technical issues; in response to any inquiry by a regulatory authority; or as we believe is required by law, regulation, or legal process.

o If we engage in a merger, acquisition, disposition, change of control, bankruptcy, dissolution, reorganization, or similar transaction or proceeding, or otherwise transfer the operations of the Avenify Site that relates to your PII, we will transfer your PII to the successor entity.

• Disclosure under the CCPA. Avenify is not currently subject to the California Consumer Privacy Act (“CCPA”). If and when Avenify does become subject to the CCPA, Avenify will revise the Avenify Site and this Privacy Notice to meet the CCPA’s requirements.

MANAGEMENT OF PII

• To keep your PII accurate, current, and complete, you can log in to your own account at www.avenify.com or you can contact [email protected]

STORAGE OF INFORMATION

• We store PII and other information that we collect through the Avenify Site on our own servers and/or on servers operated by third parties. Currently, these third-party servers are located in the United States. If, in the future, we begin to use servers that are located in other countries or in other jurisdictions, we will update this Privacy Notice. You consent to have your PII, and other information that may be collected when you use the Avenify Site collected, stored and processed on servers in the United States.

• We will keep your PII unless and until you ask us to delete it. To ask us to delete your PII, email us at [email protected]

• We dispose of your PII by deleting it from the Avenify Site database.

TRANSFER OF INFORMATION

• We may transfer information that we collect about you, including PII, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

SECURITY

• We use encryption to protect your PII as you transmit it from your computer to the Avenify Site and to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We also use a software program to stop certain kinds of attacks. But no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from the Avenify Site may not be secure. Be careful about sending us any confidential information, and keep secure any passwords, ID numbers, or other special access features that you use on the Avenify Site.

PROTECTION OF INFORMATION

• You are responsible for maintaining the privacy of your unique password and account information and for controlling access to your communications from the Avenify Site at all times.

• Your PII will be stored in secure third-party data centers. Nevertheless, we cannot (i) ensure or warrant the security of any PII that you transmit when you use the Avenify Site or (ii) guarantee that information stored on or transmitted through the Avenify Site may not be accessed, disclosed, altered, or destroyed. If any PII under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation, and where appropriate, we will notify those individuals whose PII may have been compromised and take other steps, in accordance with any applicable laws and regulations.

CHILDREN

• We do not knowingly collect PII from anyone under 13. If we become aware that a child under 13 has provided us with PII, we will take steps to remove such information and terminate the child's account.

• If you are a parent and you become aware that your child has provided us with PII without your consent, please contact us at [email protected] and we will take steps to remove such information and close the child’s account.

CONTACT INFORMATION, MANAGEMENT, CORRECTION AND DELETION OF PII

• You can change any of your PII that you have provided to us by emailing us at [email protected]

• For questions about this Privacy Notice and how your PII may be collected, stored, used, and shared, please contact us by email at [email protected]

LINKS TO THIRD-PARTY SITES

• The Avenify Site may contain links to other sites. We do not endorse or control any of those other sites. You should read the privacy policy of any site you visit before providing any PII.

CHANGES TO THIS PRIVACY NOTICE

• If this Privacy Notice changes, the revised Privacy Notice will be posted here. Please check back periodically, and especially before you provide any PII.

• This Privacy Notice was last updated on November 4, 2020.

• Previous versions: None.