1. Scope
This policy covers the InvestNow™ website, operated by Financial Infrastructure, Inc.. Where a regulated account is opened at Investor Services, that relationship has its own notice.
2. What we collect
- Information you give us — name, work email, company, role and message when you use a contact, partner, NDA or document-request form; and, where you sign a document electronically, your typed name, the document version, and the date and time.
- Technical information — network address, browser and device information, pages requested, and referring page.
- Passport information, where a Passport is created — identity, entity and ownership data, accreditation status, tax and banking details, authority and consent.
We do not knowingly collect personal information from children. The site is directed to investors, advisers, sponsors and institutions.
3. Electronic signatures
Where you accept a document electronically, we record the typed name you supply, the version of the document you accepted, the time, and the network address and browser used. Those are recorded together because they are what evidence acceptance under the federal E-SIGN Act and the Uniform Electronic Transactions Act. We keep that record for as long as the agreement is capable of being relied on.
4. How we use it
To respond to you; to deliver a document you requested; to record an agreement you accepted; to operate, secure and improve the site; to detect abuse; and to meet legal obligations. We do not sell personal information.
5. Who processes it
Stated specifically rather than as a category, because a vague answer here is not useful to you:
- Microsoft Azure — hosting for platform environments.
- Google — form submissions are transmitted to a Google Apps Script endpoint and recorded in Google Sheets in a Google Workspace tenant controlled by us. This is our current intake path for early-stage enquiries.
- Twilio — SMS and telephony notifications.
- Our hosting provider for this website, and providers of security, analytics and email delivery.
We also share where required by law, to protect rights and safety, or in connection with a corporate transaction. Any recipient is bound to protect the information and use it only for the purpose we specify.
6. Retention
We keep enquiry records for as long as needed for the purpose collected and then delete or de-identify them. Records of an accepted agreement are kept for as long as that agreement can be relied on.
An honest limitation
- Early-stage enquiry and signature records currently sit in Google Sheets. That system is not append-only, and a submission is written as structured fields and as a full record copy, so deletion of one row is not by itself deletion of the data.
- We are moving executed documents to a dedicated document-execution provider. Until then, if you ask us to delete your information we will tell you what we deleted and what the current system prevented us from deleting, rather than claiming more than we can perform.
7. Your choices and rights
You may ask us to access, correct, export or delete your personal information, and to stop sending you communications. Depending on where you live you may have additional rights, including to object to processing or to complain to a supervisory authority. Write to privacy@investnow.com. We will not discriminate against you for exercising a right.
8. Security
See our security policy. In summary: access is granted on a least-privilege basis, authorisation is evaluated per record rather than by role held indefinitely, and data is encrypted in transit and at rest. No system is perfectly secure and we do not claim otherwise.
9. International transfers
We are based in the United States and information may be processed there and in other countries where our processors operate. Where a transfer requires a mechanism we implement an appropriate one.
10. Contact
privacy@investnow.com or Financial Infrastructure, Inc., PO Box 1410, Menlo Park, California 94026-1410.
InvestNow™ is a demonstration and reference experience operated by Financial Infrastructure, Inc.. It is not a broker-dealer, alternative trading system, exchange, investment adviser or transfer agent. It is not accepting accounts and does not currently accept securities orders or offer securities for sale. Nothing on this site is an offer or solicitation of any security, a recommendation, or a suitability determination. Company data and pricing shown are illustrative and labelled as such.
Website analytics and newsletter
This site records first-party usage events — the page viewed, the referring page, and clicks on scheduling links — to understand what visitors find useful. Events are sent to our own form-intake system, are not shared with advertising networks, and no third-party analytics or advertising trackers are used. If you subscribe to our newsletter, your email address is stored in the same first-party system and used only to send the updates you asked for; every message includes a way to opt out, and you can request deletion at any time using the contact details on this page.