About This Website; Company Information

This website, www.scions.tech (the “Site”) is a website owned by Sigma Research and Consulting Company, a company with its mailing address at Langegracht 70, 2312NV Leiden, Netherlands (“Sigma Research and Consulting”, “us,” “our” or “we”).

SCIONS.tech and the Sigma Research and Consulting Company are not registered as broker-dealer or investment advisers. No investment recommendations or financial advice will be provided by us; any representations or information made on our site do not constitute and should not be construed as investment recommendations or advice.

With respect to Loan Participations and Syndicated Loans, the individual Borrower responsible for the Project is responsible for all information provided with respect to a project on the site.

With respect to any deal offerings (investing, buying, selling) that may be listed here, all deals are offered by the applicable issuer of such deals and all information included on this site is the responsibility of the same applicable issuer of such deals.

No steps has been taken by SCIONS.tech in order to verify the completeness, accuracy, or adequacy of any information. Neither SCIONS.tech nor any of its employees, agents, directors, or officers makes any warranty, implied or express, of any kind whatsoever regarding the completeness, accuracy, or adequacy of any information or the use of information on this site.

As it will be explained, when you interact with or use our site, there are various ways that we collect information from you (“user”, “your”, or “you”). Please refer to our terms of use to see the terms and conditions of using or visiting our site.

Your Consent to This Privacy Policy; Withdrawal of Consent

When you intend to use our site, first you need to consent to our collection and use of information as we have explained in this Privacy Policy, and your agreement to our Terms of Use is required. For Personal Data that we process based on your consent, you have the right to withdraw that consent. Your consent may be withdrawn by sending an email to support@scions.tech with the subject “CONSENT WITHDRAWN”. From time to time, we may update this Privacy Policy and thereafter, if you continue using our site, your continued use of our site will mean that you consent to the newest update of our Privacy Policy. Therefore, if you do not agree to this Privacy Policy, you must not use our Site. Please note that if you decide to deal on our site, or to participate in any loan posted on our site, you may be obligated to accept the terms of a separate agreement, including, but not limited to, a Loan Participation Agreement, a Subscription Agreement, a Guaranty, a Security Agreement, or a Loan Agreement.

Purpose of This Privacy Policy

SCIONS.tech respects your privacy and understands that lawful and fair means need to be used to collect personal information. Therefore, this Privacy Policy will explain what type of information will be collected by SCIONS.tech when you are using our site or the associated services. In addition here, we will explain how your collected information will be used, and how you can control it, including how to collect, erase, rectify, and export your information to another location which is not related to our site. All your information will be treated according to this Privacy Policy unless you have otherwise given us your express authorization to do otherwise. You can withdraw this authorization at any time by sending us a notification to support@scions.tech with the subject “withdraw of authorization”. However, your information may be used or disclosed by SCIONS.tech when we believe it is necessary for us to comply with a court order or other legal process.

 

Information We Collect About You

Personal Data: Personal data, which is sometimes called “personally identifiable information” in the United States (“Personal Data”) is information that can be used to identify you as an individual, such as a name, online identifier, location data, or an identification number. In addition, it can include some aspects about your social, cultural, economic, mental, genetic, physiological, or physical identity which can assist others in eventually identifying who you are. Your personal data will be collected by SCIONS.tech when you use our site in different ways such as signing up for an account, sending us an email through our site, using our site to engage in a transaction, or completing applications or forms on our site. SCIONS.tech may also collect information which may be contained on server logs, such as your Internet protocol (“IP”) address.

The types of Personal Data that we collect through our Site may include, but are not limited to, your: (1) personal name; (2) physical address; (3) email address; (4) phone number; (5) Social Security Number; (6) date of birth; (7) business name; (8) business address; (9) information from an identity document such as a passport or driver’s license; (10) job title; (11) bank account information; (12) credit card information; (13) articles of incorporation; and (14) any other Personal Data you may voluntarily provide.

Furthermore, other data that we may collect and store in our log files may include, but may not be limited to, for example, date(s) and time(s) of visits to our Site, time spent viewing pages on our Site, frequency of visits to our Site, clickstream data operating system, cookies existing on your computer, device type used to visit our Site (desktop or mobile), browser type, and sites visited before arriving at our Site. This information will be collected through automated tracking technologies, some of which are discussed below. This automatically collected information may be combined with other information we collect about you. We do this to improve our site and to improve services we offer you.

Personal Data may be obtained from third party sources. Types and uses of such third party sources may include (but may not be limited to): (1) payment facilitation services; (2) services used for anti-money laundering screening; (3) services used to verify identity and backgrounds.

How We Collect Your Personal Data

Your personal data is collected when you voluntarily provide it through our Site. For example, when you complete forms on our Site, you provide us with some information. For instance your information is provided to us when you create your user account or submit comments, feedback, or inquiries to us by email.

Our site, our service providers, or our Affiliated Companies may also collect information about you using various automated technologies on our site such as the following:

The technologies that have been mentioned above are used in gathering demographic information about our user base as a whole, tracking users’ movements around our Site, administering our Site, and analyzing trends. Third-party companies may send us reports based on the use of these technologies on an individual as well as aggregated basis. We can use this data to improve our Site.

The collection of Personal Data by cookies or other methods by third parties is not covered by this Privacy Policy. Any information you submit to a third party will be controlled by privacy policy of that third party. We do not control how these third parties collect information or by what means such third parties may use their own cookies to collect information about you. We encourage you to review the privacy policy of any third party before submitting your Personal Data.

How We Use Information We Collect About You

SCIONS.tech will use this Privacy Policy as the guide line to use the information collected about you. When your collected personal data is processed and shared by us for our own use, or when we make your personal data available to the recipients that are described below, we do these actions according to your consent or furtherance of our legitimate interests, which include protecting the security of our customers and our systems, meeting our contractual and legal obligations, operating our business, and providing the website features that you use. Your information will not be sold or rented to anyone except as may result from a transaction described in the “Transfer of Your Information” section below. The information that you provide to us, which may include your Personal Data, will be used to better serve you and to improve the experience you may have with our Site, as well as the other purposes that have been or may be described in this Privacy Policy that we regard as being in our legitimate interests. This may include the need to copy or modify the Personal Data, or other information such as textual contents or images that you provide, in order to provide you with an enjoyable and seamless experience in using our site. Please refer to the section above entitled “How We Collect Information about You” for the respective uses we make of analytics, log file data, and web beacons.

The Personal Data and other information will be used by SCIONS.tech: (1) to market our Site or our affiliates’ services, products, and websites to you and other users of our Site; (2) analyze data in order to send more targeted messages to users of our Site; (3) to conduct research and analyze the research data to enhance and improve our Site, services, and products; (4) to enable our contractors and vendors to provide and help us in the analysis, troubleshooting, operation, and marketing of our Site and other services; (5) to fulfill service and product requests; (6) to deliver email messages like service announcements, customer service, newsletters, updates, and special offers; (7) to comply with and meet any regulatory requirements for the offer or sale of securities required by law; (8) to protect our Site or the users of our site; (9) to engage in any other lawful activities we believe are consistent with the foregoing; and (10) when required by law (for example, to comply with a subpoena or similar legal process), when we deem it necessary to protect against legal liability, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

We may provide or obtain any of the above services through third parties, which may necessitate sharing Personal Data with them. With regard to use of your information for marketing, none of the information is shared beyond Sigma Research and Consulting’ affiliates.

Other than the uses described in this Privacy Policy, your Personal Data will be used to facilitate activities such as (1) performing market research and statistical analysis; (2) guarding against potential fraud; (3) facilitating payments and other transactions; (4) verifying credit information, background information, and identities; (5) maintaining communications; (6) if necessary, to work with third parties and affiliates to enforce our legal agreements, including working with any third-party service providers.

In addition to the uses described in this Privacy Policy, the Personal Data will be used by those entities seeking equity or debt financing (sometimes referred to as “issuers” of securities) as well as individuals or entities providing such financing to users of our Site (“investors” or “securities purchasers”) to facilitate activities such as: (1) posting an investor profile on our Site, which may include Personal Data such as name, relationship to the issuer of securities, if applicable, and photo (if provided); (2) facilitating transactions and payments; (3) verifying identity, including working with third-party service providers; (4) carrying out regulatory checks; and (5) maintaining communications.

Certain Personal Data may be made available on our Site and may be made visible to other users of or visitors to our site. For instance your first name and last name initial will be shown on our Site if you invest in a securities offering on our Site. A feature may be provided on our Site that will enable you to opt-in to display your whole name along with social media handles, Site investment history, your location, and a short bio. Prospective borrowers seeking financing via our Syndicated Loan offerings will have to provide more extensive Personal Data on their offering page, such as the names of their directors and officers, their background and biographies that will be viewable by other users of our Site.

There may be a feature in our Site that with enabling it you can opt-in to display your whole name as well as social media handles a short bio, Site investment history, and your location. Prospective borrowers seeking financing via our Syndicated Loan offerings will have to provide more extensive Personal Data on their offering page, such as the names of their officers and directors, their biographies and background that will be viewable by other users of our Site.

Your personal information may be shared by SCIONS.tech with affiliated companies, for the lawful purposes set forth in this Policy, as necessary to provide services and products to you.

Individuals or third-party companies are employed or contracted by SCIONS.tech so that they can perform certain services or functions on its behalf. Examples of these services from such individuals, companies, or third parties may include, but may not be limited to, providing customer service, providing marketing assistance, analyzing data, disbursement of funds, escrow services, sending e-mail, payment storing and facilitation, electronic document signing, credit/financial/accredit verification, and ID verification. These third parties may have access to, and SCIONS.tech may share with these third parties, your information, including Personal Data needed to perform their services or functions for users of our Site. However, these third parties may not use your information for other purposes. To the extent that your Non-Personal Data or Personal Data is provided to such third parties, the information will be collected and used by the third parties only to perform their prescribed functions or services.

Transfer of Your Information

Transfers Relating to Our Own Corporate Transactions. There may be times that your information may have to be transferred by us to a buyer or other successors to our business in the event of a dissolution, reorganization, restructuring, divestiture, merger, or other transfer or sale of some or all of SCIONS.tech’s assets, whether as a going concern or as part of a liquidation, bankruptcy, or similar proceeding, in which Personal Data Information held by us about our Site users is among the assets transferred.

Cross Border Transfers. As it has been mentioned and explained under the “Security” section of this Privacy Policy, the information that you provide to us is encrypted and stored securely on private cloud servers through third-party service providers that we use in the Netherlands. These server entities are contractually obligated to us to have redundancies in place to protect the data should an outage or other issues arise. We always want to make sure that your Personal Data is processed according to the provisions that have been mentioned in this Privacy Policy and the laws of the jurisdiction in which the data is stored.

The European Commission is authorized under the General Data Protection Regulation (“GDPR”) to determine whether a particular country affords Personal Data an adequate level of protection, based on such factors as the data-protection laws in effect in that country, the existence of an independent body with enforcement powers, and the international commitments that the country has made regarding the protection of Personal Data. It has been determined by the Commission that adequate protection is offered by the Netherlands, but only with respect to the Privacy Shield framework, discussed below. Our goal is to ensure that your data will enjoy the rights and protections that have been described in this Privacy Policy whenever it is transferred from the European Economic Area and Switzerland to the United States. To do so, we employ various safeguards, including the use of standard data-protection clauses approved by the European Commission.

SCIONS.tech believes that it complies with the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. If there is any question or if you have any complaint regarding the participation of SCIONS.tech in the Swiss-US or EU-US Privacy Shield, please contact us at support@scions.tech. If there is any complaint regarding the Privacy Shield frameworks that SCIONS.tech cannot resolve directly, we have chosen to cooperate with a panel established by the European data protection authorities, or the relevant Data Protection Authority for resolving disputes. Please contact us if you’d like us to provide you with contact information for your Data Protection Authority. As it has been further explained in the Privacy Shield Principles, which you can find at https://www.privacyshield.org, binding arbitration is available to address residual complaints not resolved by other means.

Third Party Websites and Services

There may be links contained in the SCIONS.tech Site that will lead to other websites and services that are not maintained by us. In addition, there may be links in other websites or other services that refer to our Site. We encourage you to be aware of the fact that these other websites are not subject to our Privacy Policy and we are not responsible for their content or for the policies or practices they apply to the treatment of your information, when you enter or leave our Site. We also encourage you to read the privacy statements of each website that you visit. We do not approve, screen, or endorse, and are not responsible for the content or the privacy practices of other websites or services.

Opt-out Policy

There may be times that we or our affiliates send you e-mail communications with general marketing information, despite the fact that none of your Personal Data is shared for marketing purposes beyond affiliates of SCIONS.tech. If it is in your preference not to receive such promotional or marketing e-mails, you may unsubscribe by emailing us at support@scions.com, or you may unsubscribe via your account dashboard, or you may choose to stop receiving our marketing or newsletter emails by following the “unsubscribe” instructions included in these emails. However, even if you choose not to receive any of these emails, there are some types of emails that you cannot choose not to receive them such as emails regarding emails responding to specific inquiries from you, legal notices we may be required to give, or specific transactions you have participated in on our Site.

In addition, please note that at times we may need to send you e-mail communications which are transactional in nature and which you will not be able to opt-out of, such as payment confirmations,  or termination or service announcements.

Accessing, Changing and Otherwise Controlling Your Personal Data

There are certain right for you about the data we process about you. This includes, among others, the right to export, erase, and rectify your Personal Data, to object to the processing of your personal data, and to access your Personal Data.

Based on your consent, we process your Personal Data and concerning this process, you have the right to withdraw your consent. You may withdraw your consent by emailing support@scions.tech with “CONSENT WITHDRAWN” in the subject line.

If we process your personal data based on the legitimate interests of our organization or the legitimate interests of third parties, you have the right to raise an objection to such processing by contacting us at support@scions.tech.

You will be able to view all of your own information that you submit. Certain highly sensitive information (such as your bank account numbers or Social Security Number) may be blocked for security reasons with only the last four digits displayed. According to our Site’s Terms of Use, you will be able to access, update, and modify the information concerning your account by going to your profile page and editing certain information that you wish to alter. For instance, by visiting your profile page and account’s settings page you will be able to change your contact information, password, your notification preferences, your e-mail address, or other login information.

You will be able to choose to remove your account and any of your Personal Data that is associated with that account. However, we will reserve the right to retain and use your Personal Data as necessary to comply with our legal obligations, enforce our legal agreements, resolve disputes, and provide our services. For example, we may need to retain archival copies of your information for compliance or legal purposes even after you have requested the deletion of your information.

It is not our responsibility to remove your Personal Data from the lists of any third-party websites or other third parties who have previously been provided with your information in accordance with this Privacy Policy.

Your personal data will generally be retained only for as long as necessary to accomplish the purposes for which we processed the data, which may include delivering the services to you for which you accessed our website.

With regard to certain types of Personal Data, you have provided consent for a retention period of longer duration than the period we would be required to preserve it in order to complete the processing for the purposes you intended. In that case, we will retain the data in accordance with your consent.

If the type of an item of Personal Data is particularly sensitive, we will shorten the retention time period that we would otherwise normally observe.

In some cases, you have provided Personal Data with the manifested intention that it be retained until you yourself initiate its removal. Nevertheless, in this case and other cases, we may be forced to delete the data earlier than you wish if, for example, you exceed the limit on the quantity of data that we can store in your account.

Automated controls may be provided by our website which will give you the freedom to delete Personal Data any time you wish. When such controls are absent, we are likely to prescribe a shortened data retention period.

If we adopt a data retention program or schedule prescribing various retention periods for different types of Personal Data, we will post it on our website.

There are certain exceptions to our policy of retaining your Personal Data for only as long as is necessary to accomplish the purposes for which you wanted to have the data processed in the first place. Your Personal Data will be retained for as long as is necessary to comply with our legal obligations, including contractual obligations, to serve our legitimate interests, and to pursue our remedies and rights and defend ourselves in litigation and other proceedings with governmental authorities, business entities, and individuals. The law may require us to preserve information, including Personal Data, that is relevant to such proceedings for a prescribed period of time. Proper institutional and technical measures will be taken by us to safeguard your freedoms and rights as required by the GDPR (General Data Protection Regulation).

Depending upon your use of various features of our website and the services we provide through our website, the nature of our interactions with you, the country or other jurisdiction in question, and the data type, the periods for which we are required to retain data can vary. We may be subject to mandatory data removal laws or data retention laws based on applicable rules of court or arbitration procedure, administrative order, data required to be retained in adversarial proceedings pursuant to a court order, government orders to preserve data in connection with an investigation, or content.

Social Media Widgets

Certain interactive mini-programs that run on our Site, and widgets, such as the “Share this” button, or social media features, such as Facebook “Follow Us” button, may be included in our Site. These features may set a cookie to enable the feature to function properly, or gather the data about which page you are visiting on our Site, or collect your IP address. Social media features and widgets are either hosted directly on our Site or hosted by a third party. Your interactions with these features are governed by the privacy policy of the third-party website providing such features.

Security

We use reasonable efforts to secure access to Personal Data in our possession but will not be liable for any failure to safeguard such information, whether inadvertent or otherwise. Information you provide to us is encrypted and stored securely on private cloud servers through third-party service providers that we use. We also take commercially reasonable efforts to store as little sensitive information as possible.

We are required to notify you without undue delay in the event of a data breach on our part causing high risk to data subjects. The notification must include at least: any measures taken by us to mitigate or remedy the breach; the likely consequences of the data breach; and the name and contact details of the DPO (or other relevant point of contact). However, we may be exempt from this requirement if: the notification requires disproportionate effort (in which case we must issue a public notice of the breach); we have taken measures to protect against the harm (e.g., suspending affected accounts); or the risk of harm is remote because the affected data are protected (e.g., through strong encryption).

Although we and our service providers, who have informed us that they also use reasonable efforts to secure Personal Data, take commercially reasonable efforts to keep secure any Personal Data, there is no guarantee that any communication over the public Internet is 100% secure at all times. Therefore, neither we nor our service providers shall be held liable for the failure to safeguard Personal Data, whether inadvertent or otherwise, except where you, as a data subject, prove that you have suffered material or non-material damage as a result of our infringement of the GDPR, in which event you shall have the right to receive compensation from us, in our capacity as data controller or processor, for the damage suffered.

In addition, it is important for you to take appropriate measures to make sure your computer and your password are protected against unauthorized access. Always make sure to log off any computer or device you use to access your account on our Site after you have finished.

Children’s Privacy Policy

The SCIONS.tech Site is not intended for use by children. No one under eighteen (18) years of age is allowed to receive our email distributions, provide any Personal Data, or use our Site. We do not knowingly solicit or collect Personal Data from children under the age of thirteen (13) or anyone under eighteen years of age. If you believe that anyone under these ages has disclosed Personal Data to SCIONS.tech, please report this to us immediately by emailing us at support@scions.com.

Changes to This Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any updates or changes will be effective immediately upon posting to our Site. If any material changes are made to our Site, commercially reasonable efforts will be taken by us in order to notify you by means of a notice posted on our Site or by email (sent to the specified e-mail address provided in your account). Notwithstanding that, you should review this Privacy Policy regularly for changes, and you can determine if changes have been made by checking the effective date at the beginning of the Privacy Policy. Your continued use of our Site following the posting of any modified versions of this Privacy Policy means you accept those changes, and agree to be bound by the updated Privacy Policy.

Your Rights Regarding Any Complaints You May Have About Our Protection of Your Personal Data.

The SCIONS.tech Site is maintained in Netherlands. By accessing our Site, you consent to and authorize the export of your Personal Data to Netherlands and its storage and use as specified in this Privacy Policy. For users in the EU, you have the right to bring a complaint with the independent public authority responsible for data protection in the EU member country of your habitual residence, place of work or place where you think our processing of your Personal Data infringed the GDPR. Before you do so, we ask that you give us the opportunity to resolve your complaint to your satisfaction within thirty (30) days of your contacting us about it at support@scions.tech.

Please check back regularly for updates to this Privacy Policy. If you have any questions regarding this Privacy Policy, please email us at support@scions.tech.