Privacy Policy

Overview

It is the Policy of Highnote Platform, Inc., to maintain a comprehensive Subscriber Privacy Policy that provides transparency to our account holders on the collection and use of their information. This policy describes how Highnote Platform, Inc. collects, uses, and shares personal information with our partners and third-party companies. Customers, meaning Highnote Platform’s Subscribers, agree to the following privacy practices outlined in the current version when utilizing Highnote Platform’s services. For California residents, please see section Information for California Residents for additional information as it pertains to your privacy. For Nevada residents, please see section Information for Nevada Residents for additional information as it pertains to your privacy. Privacy Policy Effective Date is July 17, 2023.

Types of Information

The following provides examples of the type of information that we collect from you and how we utilize that information.

Account Creation

We collect your individual and business information when you create an account with Highnote Platform. This can include, but is not limited to: your name, email address, social security number, date of birth, phone number, residential address, Internet Protocol (IP) address, device information, login credentials, business name, business address, business phone number, product details, company bank information, and financial information. We have a legitimate interest in providing account related functionalities to our users. Accounts can be used to make payments and to save your preferences and transactions.

Cookies and first party tracking

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. Our cookies collect your web browser type, IP address, language preference, referring site, logged-in state, and the time of each visit. We have a legitimate interest in using cookies to make our website operate efficiently and safely.

Cookies and Third-Party Tracking

We reserve the right to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. Third party cookies collect your email address, IP address, country code, technical data, website errors, and your actions on our site. At this time, given Highnote Platform does not collect non-essential cookies and we utilize cookies to service Highnote Platform, we do not list a banner on our site soliciting consent upon your first visit. Should this change, Highnote Platform will display a banner upon your first visit to our site soliciting your consent for these cookies. If you wish to revoke your consent, you can delete the cookies.

Email Interconnectivity

If you receive an email from us, we use certain tools (including clear gifs) to capture data related to when you open our message and click on any links or banners it contains. We have a legitimate interest in understanding how you interact with our communications to you.

Feedback/Support

If you provide us feedback or contact us for support, we will collect your name, email address, phone number, and any other content that you provide in order for us to reply. If you contact us about your Highnote Platform account, we may collect additional information to verify your identity and connection to the account. We have a legitimate interest in receiving, and acting upon, your feedback or issues.

Mailing List

When you sign up for one of our mailing lists, we collect your name, email address, and/or postal address. We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.

Transaction Data

When you initiate or perform a transaction, we collect data such as amount, date, and payment method information, to confirm and process it. This may also include information about investment or financial accounts held with third parties. This information may be shared with other third parties to facilitate the transaction. We require this information in order to perform our contract and services with you.

Transaction Monitoring and Processing

In order to process a transaction, we will first need to collect information to verify your identity and business. This may include identity verification information from third parties, as well as your company account information. We may also collect your email address and mobile phone number from third parties if you initiate or receive a transaction. We also collect information relating to the actions that you perform while logged into your account. We have a legitimate interest in the prevention, detection, and investigation of fraud, money laundering, criminal activity, and other misuse of our services. We may also have a legal obligation to collect this information or validate your identity for compliance with Anti-Money Laundering and other finance laws in the jurisdictions where we operate. We have a legitimate interest in confirming that you are an active Highnote Platform account holder and that you have initiated any transfer using your account. We have a legitimate interest in creating a trustworthy, safe, and reliable platform.

Web logs

We collect information, including your browser type, operating system, device information, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), geographic location, domain name, click-activity, referring website, and/or a date/time stamp for visitors. We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular. In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, we supplement our identity verification by comparing your information against a third-party database.

Use and Processing of Information

In addition to the purposes and uses described above, we use information in the following ways:

• To identify you when you visit our websites or use our application.
• To provide services, process transactions, or send notices about your transactions.
• To improve our services.
• To streamline the transaction process.
• To conduct analytics.
• To respond to inquiries related to support or other requests.
• To send marketing and promotional materials, including information relating to our services.
• To enforce our agreements with third parties, to resolve disputes, collect fees, and troubleshoot problems.
• For quality control and staff training.
• For internal administrative purposes, as well as to manage our relationships.
• To comply with our legal obligations.
• To enhance our security, to monitor and verify identity or service access, to combat spam or other malware or security risks, or to investigate potential violations of the law or our posted terms of use. ‍

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you complete a transaction, we will collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your transaction. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Sharing of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the below outlined situations.

Affiliates and Acquisitions

We reserve the right to share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.

Other Disclosures with Your Consent ‍

You may request that we validate your status as a Highnote Platform customer with a third party, and we will do so. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.

Other Disclosures without Your Consent

We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the provision of services by a third-party intermediary.

‍Service Providers

We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of transactions.

Your Privacy Rights

You can review and make the following choices regarding your personal information rights.

Access to Your Personal Information

You may request access to your personal information by contacting us at the address described under section Contact Information. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.

Changes to Your Personal Information

We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. Note that we may keep historical information in our backup files as permitted or required by law. If our website does not permit you to update or correct certain information contact us using the details described in section Contact Information.

Deletion of Your Personal Information

Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described in section Contact Information. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.

Objection to Certain Processing

You may object to our use or disclosure of your personal information by contacting us at the address described in section Contact Information. For example, California residents may be entitled to object, or opt-out, of having their information sold to third parties.

Automated Decision-Making

‍We may use automated decision-making to decide whether we can provide services to you based on automated identity verification. If you wish to have a human review the decision or otherwise object, you may do so by contacting us at the address described in section Contact Information.

Online Tracking

We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.

Direct Marketing and Promotional Emails

Direct marketing is considered email, post mail, and telephone outreach to inform you of our offerings and promote our products. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. Your telephone and post mail opt-out choices will last for five years, subject to applicable law. If you decide to limit direct marketing and not to receive promotional emails, we may still send you service-related communications to service your account or as otherwise allowed by law.

Revocation of Consent

If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described in section Contact Information.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law. Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

Miscellaneous

The following additional information relates to our privacy practices.

Third-Party Applications and Websites

We have no control over the privacy practices of websites or applications that Highnote Platform does not own.

Changes to This Privacy Policy

We may change our privacy policy and practices over time. When utilizing Highnote Platform’s services, you are agreeing to the current Privacy Policy and it will generally govern the use of your information. To the extent that our policy changes in a material way, Highnote Platform will notify users of the new privacy policy

Information for California Residents

California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose” as those terms are defined under California law. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the below section, Contact Information

Information for Nevada Residents

We are providing you this notice under state law. Should we participate in direct marketing, you may be placed on our internal Do Not Contact List by following the directions to limit it. Nevada law requires we provide the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702.486.3132; email: aginfo@ag.nv.gov. You may submit a written request to us using the information in the below section, Contact Information.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices please contact us at any of the following.

642 Harrison Street, Suite 100
San Francisco, California 94107
support@highnote.com

We will attempt to respond to your requests and to provide you with additional privacy-related information. If you are not satisfied with our response, you may have a right to lodge a complaint with your local supervisory authority.