Sprowtt — Growing Business in America

Legal

Privacy policy

What this software records, who can see it, and what we will not do with it.

What we hold

  • Account details: name, email, phone, organisation, role, and the city for a Portal Admin account
  • Clickwrap acceptances: the code, the version and the timestamp, kept in the operator ledger after the document leaves your profile
  • Offering and workspace content the issuer or its counsel puts there, including uploaded documents
  • Accreditation status, source, expiry and a letter reference — not your tax return and not your net-worth file
  • A Rule 147A residency method and its date — the method only, never a scan
  • Behaviour inside an offering room: sections opened, documents opened, video position, and where a visit ended
  • Meeting attendance and, where a conference was recorded, the recording

Room behaviour, specifically

Recording what a named person did while considering a securities purchase is sensitive, and it is the part of this product that most needs saying out loud. It is joined to the indication so the issuer can see what mattered and what lost people.

Capture stays switched off for an offering until the issuer's own privacy policy describes it. The report the issuer receives carries a waiver, and the waiver is rendered into the PDF as well as shown on screen, because a disclaimer that lives only on a screen is gone the moment the file is forwarded.

If you are an investor and you would rather not be measured in a room, do not enter it. The issuer's own policy governs what the issuer does with what it learns there.

What we do not do

  • We do not sell your data, and we do not sell or rent lead lists
  • We do not show one issuer's offering to another issuer's investors, because there is no catalog
  • We do not put personal data in a URL or a query string
  • We do not use your workspace content to train a third party's model

Access

Access follows the role. A Portal Admin sees their own city. A counsel firm sees its own firm's workspaces. A company sees its own. An investor sees the rooms they were admitted to. The operator sees the whole file, and every privilege change is recorded with the person who made it.