Poder Capital Privacy Policy

Date Last Revised: April 10, 2023

Poder Capital, a project of ideas42 Ventures, PBC  (“Poder”, “we” or “us”) knows that your privacy and protecting your personal information is important to you.  It’s also important to us.  This Privacy Policy describes how we protect your personal information when you visit the website located at poder-capital.com or otherwise provide information to Poder.  Poder is currently collecting information from small and medium businesses to gauge interest in our community-based lending program.   

Personal Information

Personal information refers to any information that identifies or can be used to identify a particular person. Different states (and countries) define personal information (and similar terms, such as “personal data”, “personally identifiable information”, and “PII”) to include different things, but it generally includes information such as your name, address, email address, and phone number. It may also include your computer or mobile device IP address, if that IP address can be linked to a specific person.

Generally, you are in control of whether you provide us with any personal information that we can use to identify you. If you do not wish to provide particular information, you should not do so. That may affect how we are able to interact with you and whether you can participate in our programs; however, that is your choice.

The Information We Collect Which Identifies You

We may collect and process the following personal information from you in order to gauge your interest in and evaluate your compatibility with our programs and services:

  • When you interact with us or our service provider by inquiring about our program or requesting that we contact you or subscribe you to communications about us or our programs, we will request contact and employment information from you, including your name, phone, email, business name, company website, city. This may occur when you visit our website or contact us through social media or at an event.

  • We may also obtain contact and employment information identifying you from advertising or promotional campaign partners who collect that information on our behalf, or from organizations to which you have provided that information with the understanding that they may share it with others for your potential benefit (for example, a chamber of commerce or other community organization).

  • In order to better support you, if you make an inquiry through our website, or contact us in any other way, we will keep a copy of your communications with us.

  • In order to make an initial assessment of your compatibility with Poder’s lending program for small and medium businesses, we will collect the following information: 

    • Your contact information, including your full name, email address, and phone number;

    • Information about your business, including:

      • your industry, the name of your business, its address and other contact information; 

      • annual revenue and expenses of the business, how long it’s been in operation, your ownership percentage;

    • Information about you, including your personal income and expenses, years of experience in your industry, ;

    • The purpose for which you would use a loan; and

    • financial documents supporting the above.

Poder’s Day-to-Day Use and Disclosure of Data Identifying You

Simply put, we do not and will not sell or rent your personal information to anyone, for any reason, at any time. 

Except in extraordinary cases, as we discuss below, Poder uses and discloses your personal information in a form that identifies you only for these purposes:

  • to make an initial assessment of your compatibility with Poder’s lending program for small and medium businesses –– unless and until you agree to proceed further with us, this is the only reason we will use any information you provide to us other than your contact information and any publicly available information about your business;

  • to provide you with information about Poder and our programs in response to your initial inquiry;

  • to analyze the use of our website so that we can improve it, including tracking overall usage and traffic statistics, and making the website more secure;

  • to send you any emails, texts, or other communications relevant to you and your interest or participation in our programs, including sending reminders, customer surveys, or other communications you have requested that we send;

  • unless you have opted out, to deliver communications about other products and services that we can offer to you; 

  • for research, planning, and troubleshooting problems;

  • to other third-party contractors that provide services to Poder (for example, fillable form data collection, email or message notifications) and are bound by these same privacy restrictions;

  • to enforce Poder’s legal rights; and

  • as otherwise set forth in this Privacy Policy.

We keep the personal information we collect for as long as we continue to have a business need to do so, unless a longer period is required by law. Business needs include legal, tax, accounting, risk management, and other business purposes.

Poder’s Use of Aggregated Personal information That Doesn’t Identify You

Poder may use and disclose anonymized or aggregate personal information, which does not identify you individually:

  • To understand the demographics of our user base, their interests and needs, how they use the website, and how they discover the website, us, and our programs; and

  • To develop, improve and market our programs and our company. 

How We Collect and Use Traffic and Log Data

Just like any website, Poder may also collect certain technical information (collectively “Log Data”), that is naturally available when you use our website.  Log Data includes data like IP addresses, information about the device used to access the website, unique application or advertising identifier, browser type and operating system, referring URLs, and website usage patterns.

Log Data is primarily used to improve the design and functionality of the website, and for security and similar purposes.  We collect Log Data in a variety of ways.

“Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer’s hard drive. Poder may set and access cookies on your computer to track and store information about your preferences. Poder may gather information about you through cookie technology. For example, Poder may assign a cookie to you, to limit the amount of times you see a particular notification, or to keep you logged into the website for a period of time. Please note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer. If you choose to eliminate cookies, the full functionality of the website may be impaired for you.

Some of our website pages may contain electronic images known as Web beacons, which are also called single-pixel gifs. These images allow us to count users who have visited those pages. We also may include Web beacons in e-mail messages or newsletters in order to count how many messages have been opened and acted upon. Web beacons are not used to access your personal information but they are a technique we use to compile aggregated statistics.  You may disable Web beacons in your emails by disabling HTML images in your email program, which may also affect other images in emails you receive.

Third Parties

We use third party service providers to help us analyze certain online activities. For example, these service providers may help us analyze visitor activity in the website. We may permit these service providers to use cookies and other technologies to perform these services for Poder. We do not share any personal information about our users with these third party service providers, and these service providers do not collect such information on our behalf. These services include:

  • Google Analytics, a web analytics service. For Google’s privacy practices see https://support.google.com/analytics/answer/6004245?hl=en. To opt out of data recording and analysis by Google Analytics, see https://tools.google.com/dlpage/gaoptout.

When we interact with you on social media services, the information you share with us which can be seen by anyone other than you, us and the relevant social media service is not covered by this Privacy Policy.  Only information you share with us privately (i.e., through direct messages, private chat, etc.) is covered by this Privacy Policy, in addition to the privacy policy of the relevant social media service.

Do Not Track

We do not respond to the Do Not Track setting in your browser.  While we do not use cookies to collect personally identifiable information or track users’ online activities over time or across different websites, certain of the third party tracking providers we use (e.g., Google) may be able to do so, though we do not have access to that information.  For information regarding Do Not Track mechanisms, see http://allaboutdnt.com.

Disclosure to Protect Legal Rights or if Required by Law

Poder reserves the right (and you authorize Poder) to share or disclose your personal information when Poder determines, in its sole discretion, that the disclosure of such information is necessary or appropriate:

  • To prevent prohibited or illegal activities or harm to another person; 

  • When required by any applicable law, rule regulation, subpoena or other legal process; or

  • To enforce our legal rights, including under this Privacy Policy.

Change of Control or Selling Our Business

Personal information may be transferred to a third party as a result of a sale, acquisition, merger, divestment, reorganization or other change of control. If we sell, merge or transfer any part of our business, part of the sale may include your personal information. As part of any such transaction, we will require the acquirer to agree to treat your personal information in accordance with this Privacy Policy.

Opting Out; Deleting Data.

You can opt out of most communications from us by clicking the opt-out link in emails, by emailing us at support@poder-capital.com or by other methods that we may provide which match the communication method (e.g., STOP in reply to a WhatsApp message from us).  As long as we have a relationship with you, we will need to send you certain administrative communications, so you can’t opt out of receiving those communications.

To terminate your relationship with us and request that we delete your personal information, you can email us at support@poder-capital.com.

You may be able to add, update, or delete certain information using the Settings functionality of the website when and as available or by contacting us at support@poder-capital.com. Deleted or corrected data will be permanently expunged from our primary production servers. However, portions of your data, consisting of aggregate data derived in part from your personal information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media until we overwrite it or delete it according to our standard practices. Poder keeps these backups to ensure our continued ability to provide the website and our programs in the event of malfunction or damage to our primary production servers. We may also retain personal information as required of us or our partners by applicable law or regulations or to comply with law enforcement, or as required for our legitimate business interests or to enforce our rights.

Our Security Practices

We use a combination of authentication procedures, firewall barriers, and encryption techniques (for example, we always encrypt your data when it’s at rest in our servers, and we use “https” for secured web browsing), among others, to maintain the security of your online session and to protect Accounts and systems from unauthorized access. 

No Users Under 16

We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for an Account or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at support@poder-capital.com. 

Information for Persons Outside the U.S.

If you access our website or otherwise contact us from outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law.

If you are a resident of the EEA, UK, Switzerland, or certain other jurisdictions with similar data protection laws, you have the following rights: the right to access your person, rectification or erasure of, and/or restriction of processing or objection to processing of your personal information, and in certain cases, the right to data portability. If you have any questions or want to exercise any of your rights with respect to your personal information, please contact us at support@poder-capital.com. Before we process any request, we may request personal information to verify your identity where allowed by law. Where permitted by local law, we may reject requests that are unreasonable or impractical. Finally, you also have the right to at no cost to lodge a complaint with your local data protection authorities. This right may also exist in other countries.

Updates 

We update this Privacy Policy periodically. The date last revised appears at the top of the Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, a notice will be posted on the website, a notification of the change will be posted in the Account login screen, and if we have your email address, we will attempt to reach you at that email address to inform you that the Privacy Policy has been changed. You are deemed to accept and agree to be bound by any changes to the Privacy Policy when you use the website after those changes are posted.

Contact Us 

If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, please send us an e-mail at support@poder-capital.com.