Privacy Policy

This Privacy Policy explains how ICON Capital Group, LLC (“ICON”, “Website” or “us” or “we” or “our”) collects and protects your personal information. If you have any questions that this policy does not address, please contact us at info@iconcapg.com or 5 Upper Newport Plaza Suite 200 Newport Beach, CA 92660. As explained below, we collect information from you when you interact with the Website. By accessing the Website, users (“Users” or “you”) consent to our collection and use of information as explained in this Notice, and consent to be bound by the Terms of Use and other guidelines we publish on the Website, as amended from time to time without notice. Users are required to enter into a separate agreement which may contain additional privacy notices or terms for your use of the Website and our services. This policy discloses what information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any personal or personally identifiable information that we may request will be used.

Collection of Information

When you visit our website, we automatically collect non-personally identifiable information and personally identifiable information from you regarding your usage of our Website (“Non-Personally Identifiable Information” and “Personally Identifiable Information”).

Non-Personally Identifiable Information may include, without limitation, website pages, videos, articles and presentations viewed, the amount of time spent using certain features of the Website, demographic data such as server location, frequency of visits, cookies existing on your computer, search criteria used and results, date, time, the last website you visited prior to visiting the Website, device information such as your IP and operating system and web browser, location of services, connection speed and other information which does not specifically identify you. We collect this information by using technology including, but not limited to, first part cookies and log files. “Cookies” are pieces of information that may be placed on your computer by a website for the purpose of facilitating and enhancing your communication and interaction with that website. You may stop or restrict the placement of our cookies on your computer by adjusting your web browser preferences. If you do so, you may still use our Website, but this may interfere with some of its functionality. We do not represent, warrant or guarantee that any third-party vendor plugins will be fit for purpose and free of any errors or defects. Your use of any third-party plugins is done at your own risk. We reserve the right to change vendors at our sole discretion without prior written notice. SEC Regulation S-P requires us to provide a statement to you once each year regarding the use of your nonpublic financial information. We strongly believe in protecting the confidentiality and security of personal information we collect from you.

We also collect information from you when you sign up for an account, fill in forms on the Website, or send us and email through the Website which may enable us to identify you personally, such as your email address, postal address, telephone number, mobile number, age, date of birth, Internet protocol address (“IP address”) or physical address (“Personally Identifiable Information”). Once a company posts an offering on the Website, certain information about the offering will be visible to users.

Use of Information

You consent to our use and disclosure of any information submitted to us via Website, or information collected when you access the Website in any manner permitted by law, and you acknowledge that you have no expectation of privacy, confidentiality or privilege in such information.

Non-Personally Identifiable Information and Personally Identifiable Information must be supplied during the investor registration processes in order to (a) enable registered users to login to the Website, (b) determine investors’ eligibility to invest in offerings posted on the Website, (c) verify your identity, (d) guard against potential fraud. We will use this information to (a) provide, improve, and personalize our Website, (b)To monitor and analyze usage trends and preferences, (c) To processes payments and investments, (d) To communicate with you, including for administrative, informational, promotional, and marketing purposes, and to respond to your requests or inquiries.

Certain personal information must be supplied during the investor registration process or prior to making an investment in order to (a) enable you to log in to the Website, (b) establish your eligible investor status, (c) verify that you are at least 18 years of age, (d) guard against potential fraud, (e) contact you if there is a problem with your account, (f) complete certain educational requirements, and (g) maintain regular communications with you as may be necessary to inform you of upcoming investment opportunities, Website updates and required disclosure and updated mandated by law. This information may include your name, email address, home address, phone number, date of birth, social security number and/or tax identification number, employer, and job title, annual income, your bank routing number and bank account number. We may provide any of these services through third parties, such as escrow agents and technology service providers, which may necessitate sharing Personally Identifiable and Non-Personally Identifiable Information with them. We will disclose Non-Personally Identifiable Information and Personally Identifiable Information to third party service providers to facilitate transactions on the Website.

We may also use and disclose Personally Identifiable and Non-Personally Identifiable Information: to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our Website or network; to protect and defend our rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of our business or assets. Any successor in interest to our business would acquire the information we maintain, including Personally Identifiable Information, and may alter the terms of this Privacy Notice.

Third Party Websites and Services

The Website contains links to other websites and services not maintained by ICON. In addition, other websites and services may also reference or link to the Website. We encourage you to be aware when you enter or leave our Website, or surf the Internet, and to read the privacy statements of each websites and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.

If you decide to register through, or otherwise grant access to a third party social networking or authentication service, that we may make available (“Integration Service“), such as Facebook, LinkedIn, or Twitter, we will collect certain personal information that you have provided to the Integration Service (such as your name, email address, photo, and other information you make available via the Integration Service) and an authentication token from the Integration Service.

You may revoke our access to your account on the Integration Service at any time by updating the appropriate settings in the account preferences of the respective Integration Service. You understand that certain features of our Website may not be available to you if you choose to remove our access to your account with the Integration Service.

Third Party Pixels and Cookies: When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address or other Personally Identifiable Information. We (or service providers on our behalf) may then send communications and marketing to these email addresses or other methods of communications.

Opt-out Policy

We may send you e-mail communications with updates and marketing materials. If you prefer not to receive e-mails from us, you may unsubscribe completely by emailing us at: info@iconcapg.com to unsubscribe. Please note that opt-out requests may take up to four business (4) days to process.

You are permitted to change your email address, password, name, and biography at any time by accessing your profile page. We do not permit users to delete their account entirely but instead to designate it as inactive. Once an account is designated as inactive, the user can no longer login into the Website but the existing activity that was already made public will remain visible.

You may also clear cookies from your computer via your web browser settings. You may also wish to use a Google Analytics opt-out browser add on. Information on this option is available at: https://tools.google.com/dlpage/gaoptout

We are not responsible for removing your Personally Identifiable Information from the lists of any third party who has previously been provided your information in accordance with this notice.

Data Deletion

At any time, a user may request the data being collected be removed by emailing info@iconcapg.com. If a request is received, ICON will remove any data unless it is required by law, for audit purposes, or other internal needs of the Company.

Please note that if you request to delete your data, or choose not to accept, cookies from our Website, you may not be able to utilize many features of our Website.

Communications

When you register on our Website you will receive emails that confirm specific actions you requested. These notifications are typically sent to notify you of a change in status, or for legal or security purposes. For example, you will receive notifications confirming your registration, the successful verification of email addresses and bank accounts, and the successful submission of investment orders; you will receive notifications regarding certain changes to legal agreements and privacy disclosures; and you will receive progress updates on the status of investment orders. These are transactional notifications that you generally cannot opt out of receiving. We may also send you responses to emails you send us, if appropriate or applicable. From time to time, we will also send user surveys, requests for user feedback regarding user experience and Website operations, newsletters, event notifications, or marketing offers from us or from us on behalf of our marketing partners.

ICON is not responsible for any personal information that investors may choose to reveal about themselves in their screen names, funding requests, or blog/forum posts. If you use our interactive forum on this Website, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of this forum, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in this forum or through the Website.

Security

We use our commercial reasonable best efforts to secure access to Personally Identifiable Information in our possession but will not be liable for any failure to safeguard such information, whether inadvertent or otherwise. Personally Identifiable Information is also stored with third parties who have informed us that they also use reasonable efforts to secure access to Personally Identifiable Information, but we will not be liable for the failure of any third party to safeguard Personally Identifiable Information, whether inadvertent or otherwise. We can provide no guarantees that our security measures will be adequate or effective and prevent the growing trend of cybercrimes which have been committed against larger more advanced financial institutions in recent years.

Children’s Privacy Policy

The Website is not intended for use by children or teenagers, especially those under age 18. No one under age 18 is allowed to use the Website, provide any personal information or receive our email distributions. We do not knowingly solicit or collect Personally Identifiable information from children or teenagers under the age of eighteen. If you believe that a minor has disclosed Personal Information to ICON, please report this to us by emailing info to info@iconcapg.com

Changes to Notice

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this notice at any time. Any changes or updates will be effective immediately upon posting to the web Website. You should review this notice regularly for changes, and can determine if changes have been made by checking the Effective Date below. Your continued use of our Website following the posting of any changes to this notice means you accept such changes.

ICON’s Security Policy

ICON takes steps to safeguard your personal information through vigorous physical, electronic and operational policies and practices. Data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls (there is no direct communication allowed between the database server and the Internet) and servers with hardened operating systems are all housed in a secure facility. Access to the system, both physical and electronic, is tightly controlled and limited to only those employees or third parties who have a need to know. We do not allow visibility of your Social Security number, bank account information, or credit card information via the Website. Further, we also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that when you connect to our Website you are actually on our Website. SSL also ensures that all data entered into the Website are encrypted. To verify that SSL is being used, look for the key or padlock icon on your browser.

Although ICON has a stringent process in place to prevent fraudulent persons from using stolen identities to acquire loans, there are still limited times when identity theft occurs. ICON will work with law enforcement authorities to track down and prosecute persons who have committed identity theft.

Passwords

At a minimum, we require the use of both numbers and letters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password, including the use of a security question. Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password as a means of identifying yourself. You should never share your password with anyone, and if you ever receive an email purporting to come from ICON that asks for your password, you should immediately report this development.

In addition to our own substantial efforts, you can take several precautions to protect the security of your computer and personal information. For instance, you can start by using a well-chosen password. You should avoid using any information that others can easily learn about you, such as a family member’s name or birthday, and you can also use special characters in place of letters. In addition, we recommend that you change your password frequently.

You can install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our Website, be sure that you log out and close the browser window.

To protect your account, we send automatic notifications confirming certain actions taken on your account, such as changes to a password or external linked account. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered through these notifications can be undermined if other people have access to your email account. Therefore, you might consider restricting access to the email account you registered with on this Website and/or changing your password on that email account frequently.

If you use a computer that is accessed by other people, such as in a public library or Internet cafe, we recommend that you take special precautions to protect the security of your Account and personal data. When you are finished using our Website, you should log out completely, then close the browser window and clear the browser’s cache files.

You should also be aware of fraudulent attempts to gain access to your account information known as “phishing.” Phishing is a tactic used by scammers in which unsuspecting people are brought to a website by a genuine-looking email purporting to be from a legitimate company. The phony or “spoof” email takes the person to a website that looks legitimate but in fact is not. Either in the email itself or on this fake Website, scammers will ask for login information to gain access to people’s accounts and withdraw their money.

ICON will never ask you for your login information in the context of any email. In general, you can protect yourself against phishing by never providing personal or login information via an email—instead, go the website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain. In the case of ICON, you should always ensure the URL begins with https://iconcapg.com.

Compliance with State and Federal Laws

This privacy policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state that is charged with overseeing privacy rights of consumers. Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our membership. We may also be required to maintain your personal information for at least seven years in order to be in compliance with applicable federal and state laws regarding recordkeeping, reporting and audits.

Changes to This Policy

Any updates to the Privacy Policy become effective when we post the updates on the Website. Your use of the Website following the update to the privacy policy means that you accept the updated privacy policy.

For additional information, or if you have any questions regarding this policy or the privacy practices at ICON, please submit your questions or comments directly to info@iconcapg.com via email. Any personal information you submit will be used solely to respond to your requests.

Applicable Law and Jurisdiction

The Website is maintained in the United States of America. By accessing the Website, you authorize the export of Personally Identifiable Information to the USA and its storage and us as specified in this Privacy Notice.

This Privacy Notice shall be governed by, construed and entered in accordance with the laws of the State of New York applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Notice shall be brought and heard either in the federal and state courts of the State of Illinois. You consent to the in personam jurisdiction and venue of such courts. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION, OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

Effective Date

This Privacy Notice was last updated on May 23, 2024

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