(Last updated March 2023)

This Privacy Policy describes the types of information that SJF Ventures and its affiliates (“SJF”, “we” or “us”) collects on the Sites, how we use such information and to whom and under what circumstances we may disclose it. This Privacy Policy applies to our website (https://www.sjfventures.com), our investor portal (located here), our mobile sites, our use of social media sites (collectively, the “Sites”) and any other personal information obtained when you call, email or otherwise communicate with SJF.  By accessing the Sites on any computer, mobile phone, tablet, or other device (collectively, “Device”) or otherwise interacting with SJF, you agree to the terms of this Privacy Policy. If you do not agree to the policy, please do not use the Sites.

We may modify this Privacy Policy at any time and will post the current version on the Sites. We encourage you to periodically review our Privacy Policy to stay informed about how we are using the information we collect.

Information That You Give Us

We collect personal information from you when you submit it to us, including by: (1) registering on the Sites; (2) signing up for our newsletter or other social media; (3) contacting us; (4) participating in a Site promotion or survey; or (5) generally using the Sites. This information may include, for example, your name, email address, username, password, mailing address, billing address, telephone number, date of birth, or other contact details you may provide to us when you register or update an account, sign up for email communications, or join our mailing list.  We may also collect payment information such as bank account information and numbers or other financial information you share. We may combine the information we collect from you with information we receive about you from other sources, such as address update services.

Among the information we may collect from you, the following types of information are characterized as “Sensitive Personal Information”: your social security number, driver’s license, and state identification card numbers; precise geolocation (if you permit us to obtain your precise geolocation); your racial and ethnic origin; your biometric data; the combination of your email address, financial account, debit card or credit card with security or access code, password or other credentials allowing access to your account.

In some jurisdictions, individuals may have the right to opt-in or withdraw consent for certain uses of your personal information, including your Sensitive Personal Information. If you reside in such jurisdictions, you may have additional rights which are detailed below: see “Access, Correction, & Deletion” and “Your California Privacy Rights.”

Information We Collect Automatically

When you visit the Sites, we may collect certain information from you, including your Internet Protocol (IP) address, MAC address, browser type, operating system, device-identifying information, the specific web pages visited during your connection, and the domain name from which you accessed the Sites. In addition, we may collect information about your browsing behavior, such as the date and time you visit the Sites, the areas or pages of the Sites that you visit, the amount of time you spend viewing the Sites, the number of times you return to the Sites, keystrokes typed, movement of the mouse or pointer, and other clickstream data. We may also use non-personal or aggregated information for statistical analysis, research, and other purposes.

Like many commercial websites, we analyze how visitors use our Sites through what is known as “cookie” technology. A cookie is a small text file that is placed on your computer when you access the Sites and allows us to recognize you each time you visit the Sites. We may use cookies to: (1) allow you to use the Sites without having to re-enter your username and password; (2) enhance or personalize your usage of the Sites and your shopping experience; (3) monitor usage of the Sites; (4) manage the Sites; (5) improve the Sites and our products and services; and (6) provide you with interest-based ads. For more information on our advertising, see below: “Interest-Based Advertising.” If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Sites, or that we may put on our Sites in the future. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness.

We may also use web beacons on the Sites, in our emails, and in our advertisements on other websites. Web beacons are tiny graphic images that are used to collect information about your visit to the Sites, such as the pages you view and the features you use, as well as information about whether you open and/or act upon one of our emails or advertisements. We may also collect the URL of the website you visited immediately before coming to the Sites. Web beacons help us analyze our Site visitors’ behavior and measure the effectiveness of the Sites and our advertising. We may work with service providers that help us track, collect, and analyze this information.

We may combine and draw inferences from the information we collect through cookies and web beacons with other information we have collected from you or information from other sources in order to draw create a profile about reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Information We Collect From Other Sources

We may also collect certain information from third parties, including legal information (e.g., fraud checks or flags raised about your transactions, the payment card you want to use, payment card refusals, suspected crimes, complaints, claims, and accidents) and, if you interact with us through a social media service or log in using social media credentials, information from your social media account (e.g., your name, email address, age, gender, and location).

Use of Information

We may use the information we collect from and about you for any of the following purposes: (1) to fulfill your requests for products or services; (2) to respond to your inquiries; (3) to send you confirmation emails; (4) to review usage and operations of the Sites; (5) to address problems with the Sites, our business, or our services; (6) to protect the security or integrity of the Sites and our business; (7) to monitor the Sites for compliance with our Terms of Use and the law; (8) to contact you about updates to our Sites, newsletters, and other informational and promotional materials from us and third party marketing offers from our trusted partners, as well as from other companies; and (9) to provide interest-based advertising to you based on the way you browse and shop on the Sites and other platforms (subject to applicable laws and consent requirements).

We use your personal information for the following key legal purposes:

• to contact you: subject to applicable law, we or our third-party service and business providers may send you communications; especially if you have subscribed to one of our services or regarding the Site. Such communications are designed to make your experience of our Site more efficient and may include, but are not limited to, communications about SJF and other notifications including important news that could affect your relationship with us. Where required under applicable data privacy laws, we will not send you marketing communications without your prior consent;
• for legal purposes: we may use and share personal information for legal purposes, including financial, regulatory, tax and other legal obligations and to respond to governmental or regulatory requests or subpoenas or for litigation purposes;
• for our legitimate interests and those of a third party: we may use your personal information to manage our legal, regulatory, financial and business requirements, including obtaining legal advice, in the course of disputes and litigation, internal and/or regulatory investigations and other legitimate interests; we also use your personal information for our legitimate marketing purposes and we may share your data with third parties, such as our sponsors, where we consider this meets our legitimate interests or those of our sponsors, whilst respecting users’ data privacy rights;
• for our business purposes: we may use your personal information to help us learn about the usage of our Sites, identify and fix issues with our Sites, and otherwise manage the objectives of our organization;
• for other purposes: subject to applicable law, we may use your personal information for additional purposes in connection with the Sites or SJF’s business, where you have provided your prior consent.

If you sign up for our mailing list, we will send you informational emails about offers of services. At any time, you can ‘unsubscribe’ yourself from our email list simply by clicking the ‘unsubscribe’ button.

If you do not wish to receive communications from us about special offers and promotions, you can opt-out of receiving these communications by following the instructions contained in the messages you receive. Even if you opt-out of receiving these messages, we reserve the right to send you certain communications relating to the services we provide, and we may send you service announcements and administrative messages. We do not offer you the opportunity to opt-out of receiving those communications. For more information about interest-based advertising, including how you can manage advertising, please see below “Interest-Based Advertising.”

Disclosure of Information

We may disclose information collected from and about you as follows: (1) to our related companies and service providers, to perform a business, professional, or technical support function for us; (2) to our marketing partners, advertisers, or other third parties, who may contact you with their own offers; (3) as necessary if we believe that there has been a violation of our Terms of Use or of our rights or the rights of any third party; (4) to respond to legal process (such as a search warrant, subpoena, or court order), internal investigations, regulatory enquiries, or requirements to share information and/or provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and (5) in the event that our company or substantially all of its assets are acquired, your personal information may be one of the transferred assets. We may also disclose your personal information with your express consent. We may share aggregate, non-personally identifiable information about Sites’ users with third parties.

Please note that if you voluntarily submit any personal information for posting on the Sites, such as a review or a blog post, the information becomes publicly available and can be collected and used by others, so you should use care before posting information about yourself online.

Interest-Based Advertising

We may use third-party advertising companies that use tracking technologies to serve our advertisements across the internet. These companies may collect information about your visits to the Sites and other websites and your interaction with our advertising and other communications. These advertising companies serve ads on behalf of us and others on non-affiliated sites, and some of those ads may be personalized, meaning that they are intended to be relevant to you based on information collected about your visits to the Sites and elsewhere over time. Other companies may also use such technology to advertise on our Sites.

You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in. If you would like more information about this practice and to know your choices concerning interest-based ads, visit:

http://www.networkadvertising.org/choices/
http://www.aboutads.info/choices
In Canada, please visit: http://youradchoices.ca/choices/
In the EU, please visit: http://www.youronlinechoices.eu/

Access, Correction, & Deletion

We respect your right to access and correct your personal information. You may access your personal information by signing into your account. From there, you can correct or modify your information. You may also exercise your rights, subject to applicable laws, to request that we delete or restrict access to your personal data or object to our processing of your personal information or ask that we provide it to another provider. We may still need to retain it for legally permitted purposes, and this will be explained to you if necessary.

If you need assistance correcting or updating your personal information or would like to request that we delete your personal information, please contact us using the contact information detailed in the “Contact Us” section below.

Retention of Personal Information

Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for a period of 5 years thereafter in the event of any potential disputes, unless otherwise provided in agreements between you and SJF or as required or authorized by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased, or made de-identified.

Security

We maintain reasonable and appropriate measures designed to maintain information we collect in a secure manner. We have taken certain physical, electronic, and administrative steps to safeguard and secure the information we collect from visitors to the Sites. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect, and we cannot promise, and you should not expect, that your information will be secure in all circumstances.

Children

The Sites are not directed to children, nor do we knowingly collect any personal information from children under the age of thirteen without verifiable parental consent. If you believe that a child has provided personal information to us, please contact us promptly as described below, and we will endeavor to investigate and delete such information from our systems.

Third-Party Websites

The Sites may contain links to third-party websites, such as social media sites like Facebook and Twitter, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policy posted on any external site before disclosing any personal information. Please contact those websites directly if you have any questions about their privacy policies.

Right to Removal of Posted Information—California Minors

If you are under 18 years of age, reside in California, and have a registered account with us, you have the right to request removal of unwanted information that you publicly post on the Sites. To request removal of such information, you can contact us as provided below. Upon receiving such a request, we will make sure that the information is not publicly available on the Sites, but the information may not be completely or comprehensively removed from our systems and databases.

Visitors from Outside the United States—Cross-Border Transfer

The Sites are hosted in the United States. If you are visiting the Sites from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries in accordance with this Privacy Policy. The data protection and other applicable laws of the United States or other countries may not be as comprehensive or protective as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Sites and/or providing personal information to us, you acknowledge and, to the extent required, also consent to transfer of your information to our facilities as described in this Privacy Policy.

Right to Lodge Complaints

We are transparent about the ways in which we collect and use personal information and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.

Changes to This Privacy Policy

We may change this privacy policy from time to time, including as required to keep current with rules and regulations, new technologies and security standards. When we do, we will post the change(s) on our Sites. If we change the policy in a material and retroactive manner, we will provide appropriate notice to you.

Contact Us

If you have questions or concerns about this Privacy Policy or how we collect and use the information of our customers, you can contact us by emailing us at finance@sjfventures.com or by postal address at 200 N. Mangum Street, Suite 203, Durham, NC 27701 ATTN: Privacy Inquiry, or by telephone at (919) 530-1177.

If we need, or are required, to contact you concerning any event that involves your information, we may do so by email, telephone, or mail.