Privacy Policy

DATED: NOVEMBER 2023

This is a sample writing that does not have legal power and its only purpose is a place holder for the website.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING AND USING THIS WEBSITE OR OUR MOBILE APPLICATION, AS APPLICABLE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY IN ITS ENTIRETY. IF YOU DO NOT AGREE WITH THE TERMS IN THIS POLICY, PLEASE DO NOT USE OUR PLATFORM. Each of Ocean Shore Capital.com, any related URLs, and our mobile application (each and collectively, as appropriate, the “Platform”) is brought to you by Ocean Shore Capital, LP, located at Office No.12 On 19th Floor, Ho King Commercial Centre, No.2-16 Fa Yuen Street, Mongkok, Kowloon, Hong Kong, and its affiliated companies (collectively “Ocean Shore Capital,” “we,” “us,” or “our”). This privacy policy provides information about our policies and procedures regarding the collection, use, and disclosure of personal information through the Platform from visitors and registered users of the Platform (the “Privacy Policy”), and is incorporated into and part of our Terms of Use, which govern your access to the Platform and/or your use of the Site and Platform Content (as defined in the Terms of Use) and the services made available on or through the Platform, including when you access, use, or download any products, services, features, content, widgets, materials, or other tools offered by Ocean Shore Capital (collectively, the “Service”). Unless otherwise defined herein, capitalized terms have the meanings given in the Terms of Use. If you have comments, suggestions, questions, or concerns about our Privacy Policy, please contact us at support@Ocean Shore Capital.com

Your privacy is very important to us. Ocean Shore Capital is committed to maintaining your privacy. This Privacy Policy is intended to inform you of:

The types of information we collect
How we use information we collect
How we share information we collect
How we safeguard information we collect
Other important privacy information

This Privacy Policy applies to you whenever you access or use any domains or subdomains of the Platform, or when you access or use the Service. This Privacy Policy does not govern information you choose to exchange directly with other users of the Platform, including communications or transactions with other individual users, as we have no direct control over the collection or use of this information. Please use appropriate precautions in sharing your information with these users.

Please note that your relationship with Ocean Shore Capital is also governed by our Platform Terms of Use and the transaction documents that you may enter into in connection with making an investment through our Platform. Ocean Shore Capital also has relationships with third parties for purposes of cookies served on our Platform, as detailed below. You are encouraged to carefully review these sections as well.

Types of Information We Collect

To provide our Services, and facilitate exchanges between users of the Platform, we obtain personal information directly from you and obtain information about you indirectly through electronic communications and third parties (collectively, "Personal Data").

User Supplied Membership Information

Depending on the Service you seek to access, we may require that you provide some or all of the following types of Personal Data :

Name
Address
Email Address
Phone Number
Entity Information
Social Security Number (or equivalent)
Financial Information
Joint Owner Information
Date of Birth
Accreditation Status
Employment
Citizenship
Payment Information
Investment Experience
Investment Suitability Information

Our membership registration process, surveys and questionnaires may request that you provide other information that you may, at your option, choose to provide or withhold. Any information you provide will be subject to this Privacy Policy. If you contact us by email, we may keep a record of your contact information and correspondence, and we may use your email address and any information to provide to us in your message, to respond to you.

Verification Information

If required to help us verify your identity, you may provide us a copy of your driver's license, passport or other government issued Identification. If required to help us verify your residence, you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti-money laundering laws, US Treasury department rules or regulations or other legal requirements. If you seek to invest through an entity or corporation, you may provide us with documentation relating to the entity's jurisdiction of formation, legal status and ownership. By providing the verification information and documents mentioned above, you also provide us information within those records, which may include characteristics of protected classifications like your sex, age, national origin, and citizenship.

Banking Information

To make an investment in securities offered through our Platform, you must provide us and our third party financial providers or partners with certain account and other payment information, such as information needed to make payment via ACH, wire, electronic checks, cryptocurrency, foreign currency or any other payment method accepted by us at such time. Our membership registration and buyflow process provides additional details on the types of payment information needed. For members who link or verify bank accounts through our Platform and/or one of these third-parties, you may further agree to your personal and financial information being transferred, stored, and processed by this third-party in accordance with their respective privacy policies.

Automatically or Passively Collected Information

In addition to information you directly provide, we automatically or passively collect information when you access or use our Service, including, but not limited to, your IP address, device identifiers, click path, use of our Platform and other electronic data. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users to help us understand how our Platform is being used, and for security and monitoring purposes. To determine whether your computer is supported by our system, we may collect additional technical information about your operating system and browser, as well as the presence of any software that our Platform may require to operate with your computer, or other third party software on your computer.

Additionally, we may collect, store, and use “cookies”. A “cookie” is a small amount of data, often including an anonymous unique identifier, that is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience to make it easier for you to use a website upon a future visit, as well as to help you navigate between pages efficiently. We may include cookies on our Platform and use them to recognize you when you return to our Platform. You may set your browser so that it does not accept cookies. However, cookies must be enabled on your web browser if you wish to access certain personalized features of our Service. We encourage you to carefully review this section to learn more, and explore your opt-out options for certain cookies that are not necessary to become a member on our Platform.

Types of cookies used on our site:

Session Cookies: These cookies are automatically erased whenever you exit the Platform. We use these cookies to grant users access to places on our Platform, and enable actions they must be logged on to do.
Persistent Cookies: Persistent cookies usually have an expiration date in the future, and remain in your browser until they expire, or you manually disable them. Persistent cookies are used in order to track member usage patterns of our Platform, and understand what you do on our Platform.
Third Party Cookies: We use third-party cookies for most of our user tracking. We may use cookies to determine users logging in or if they signed up forto web push notifications.

TYPE OF COOKIES

WHO SERVES THE COOKIES

Strictly Necessary Cookies

Ocean Shore Capital

Performance and Functionality Cookies

Ocean Shore Capital

Analytical Cookies

Ocean Shore Capital, Mixpanel

Advertising Cookies

Adroll, Barometric, Bidswitch, Bing, Dianomi, Google Marketing Suite, Jeeng, Katz, Linkedin, Mountain, Outbrain, PandoraPippio, Quora, Taboola, Tapjoy, Twitter, Wisepops, Yahoo

Social Media Cookies

Facebook (Meta), Linkedin, Pinterest, TikTok, Twitter

How Do I Control Cookies

There are multiple ways to control how cookies are used on your Ocean Shore Capital platform and your devices.

Cookies within the Ocean Shore Capital Platform. By using the Ocean Shore Capital Platform, you consent to the use of types of cookies detailed herein.
Advertising ID. You can customize your device settings to control advertising ID:
On Apple devices: enable "Limit Ad Tracking" in your device settings.
On Android devices: enable "Opt out of Ads Personalization" in device settings.
Third Party Cookies Opt-Outs. Many of the third-party and social media cookies as listed above also prove opt-outs on their own websites. You can find details on their own policies, as listed above in our cookies used.

Please note that removing or rejecting all cookies could affect the functionality of the Platform and its services.

For more information about cookies, please visit www.allaboutcookies.org if you are located within the United States. If you are located within Europe, visit www.youronlinechoices.eu.

Pixels

We may also use so-called "pixel tags," which are small graphic images (also known as "web beacons" or "single-pixel GIFS"), to tell us what parts of our website users visit, inform us of the reach and efficacy of our advertisements, or to measure the effectiveness of searches users perform on our Site. Pixel tags also enable us to send email messages in a format customers can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our users.

Some web browsers transmit “do-not-track” signals to websites. At present, our Service is not designed to respond to these signals or similar mechanisms from browsers.

We may send email messages that use a “click-through URL” linked to Platform Content. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply do not click text or graphic links in the email messages, or notify us here here.

Usage Information

We collect certain information about you when you visit and interact with the Platform and use of our Service. We collect information about when you use Services, the pages within the Platform you visit, the links you click on, the type, size and names of files you upload or download, and the search terms you use. If you invite others to use the Platform, we retain information about your referral.

We collect information in connection to which you become a party through our Services, including your participation in primary offerings via the Platform and secondary purchase and sale transactions through the secondary market bulletin board. Transaction data includes, without limitation, the terms on which you purchase or sell securities and information relating to price, size, volume, class of securities, offers, acceptances, transfer restrictions, and any derivative data related thereto.

Third-Party Information

We collect information about you from third-party sources with which we maintain various commercial relationships. We utilize a third-party identity verification service provider to help us confirm your identity, prevent fraud, money-laundering, and other illegal activity, and to satisfy legal requirements relating to the Service. We also receive information about you and your activities from third-party service providers, such as Google, LinkedIn, Meta, and other advertising, social media, and market research partners who provide us with information about you, and/or your engagement with and interest in, our Service. We may also receive information about you from our third-party marketing partners, under referral programs, individual retirement account service providers, partnership agreements, and/or under joint marketing arrangements.

BY USING THE SERVICE, YOU AGREE TO THIS PRIVACY POLICY AND CONSENT TO THE USE OF TRACKING TECHNOLOGIES LIKE COOKIES, PIXELS, AND USAGE AND THIRD-PARTY INFORMATION, AS SET FORTH IN THIS PRIVACY POLICY.

How We Use Information We Collect

We may use information we collect about you for the following commercial purposes:

To administer, operate, facilitate and manage your relationship with Ocean Shore Capital and deliver the Services.
To facilitate our business operations, including fulfilling our legal and regulatory requirements such as identity verification, validation, anti-money laundering and "Know Your Customer" protocols.
To determine your eligibility to invest.
To enable you to subscribe for securities, make and receive payments and execute transactions.
To satisfy our record keeping and transfer agency obligations under applicable laws, rules and regulations.
To communicate with you about the Service and target our marketing, advertising, and sales efforts to enhance your user experience and increase engagement. These communications may alert you to new services, offerings, features, content, and promotional events related to the Service.
To provide you with information about our current Services, including onboarding materials, the availability and terms of new investment opportunities, reminders, information about your previous investments.
To verify your identity, accounts, and activity; to monitor suspicious or fraudulent activity; and to identify violations of Service-related policies.
To debug, identify and correct errors with the Platform and/or Service;
On a de-identified, aggregated basis, for research and development activities, including to analyze how you use the Service to help us understand usage patterns and identify whether there are problems with the Services or areas ripe for improvement;
To contact you or, if applicable, your designated representative(s) by mail, telephone, text message, electronic mail, facsimile, etc., in connection with your relationship with Ocean Shore Capital, including with information and updates about our Service.

In addition, if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, creation of a trust or other affiliated entity, receivership or sale of Ocean Shore Capital' assets, or other corporate transaction affecting Ocean Shore Capital, your information may be shared, transferred or sold under a duty of confidentiality as part of a transaction as permitted by law or by contract.

By using the Service, you consent to receiving calls and messages, including auto-dialed and pre-recorded message calls, and SMS messages (including text messages) from us, at any telephone numbers that you have provided or may provide in the future (including any cellular telephone numbers). Your cellular or mobile telephone provider will charge you according to the type of plan you carry. You can opt out of receiving these types of communications from us by following the directions provided elsewhere in this Privacy Policy.

If your relationship with Ocean Shore Capital ends, we will continue to treat your Personal Data, to the extent we retain it, as described in this policy.

How We Share Information We Collect

We do not buy, sell, or share personal identifying information from, to or with third parties for their direct marketing or similar purposes without your knowledge and consent. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or Services in exchange for your information.

The manner in which partners, service providers and others with whom we share and/or disclose your information is governed by the policies of such parties, and we will have no liability or responsibility for the privacy practices or other actions of any such parties. Generally, you can easily recognize when one of our partners is associated with a service. However, certain parties may provide services anonymously, and, in that case, we will only share information that is directly related to the applicable service(s). This may include the incorporation of your Personal Data into databases maintained to validate information for identity verification, including verification for anti-money laundering and “Know Your Customer” protocols.

The primary situations in which we share your data are as follows:

Partnering Arrangements: We employ other companies to perform functions on our behalf, such as a broker dealer that underwrites and solicits investment in our offerings, service providers that assist in the administration of our Platform and our advertising and marketing efforts, identity verification services such as Onfido, data analytics companies that help us target our offerings, marketing partners such as Braze, Windfall and Hubspot, Individual Retirement Account services providers, such as Alto IRA and payment providers such as Dwolla, Plaid,Goldman Sachs, First Republic, Modern Treasury, Checkout.com, Synapse, Templum, and DriveWealth. We may need to share your information with these companies, and they may access this information so long as you are a member of the Platform.
Potential Business Combination: We may also transfer your Personal Data to a third party as a result of a business combination, merger, asset sale, reorganization, or similar transaction, or to governmental authorities when we reasonably believe the transfer is required by law or appropriate to respond to legal process. We will also share your information with third-party companies, organizations, or individuals if we have a good faith belief that access, use, preservation, or disclosure of your information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims, protect against harm, or protect our legal rights or safety. In any such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Data, give you an opportunity to consent to such changes. Any third party with whom we share your data will be required by our agreement with the party to provide the same or equal protection of such data as stated in our Privacy Policy.
Service Providers: To operate the Service we share information about you as needed with our service providers, including financial institutions, broker-dealer(s), accountants, auditors, lawyers, payment processors, information technology consultants, advisors, and our affiliates. We only share information to the extent required to fulfill our obligations to you and to regulators, and to operate the Platform and the Service. The information is only shared so long as you are a member or user of the Platform or Service.
Affiliates: We routinely share information with companies closely related to us – our "Affiliates" – for certain purposes under this Privacy Policy. "Affiliate" means an entity that controls, is controlled by, or is under common control with Ocean Shore Capital, whether the control results from equity ownership, contract, overlapping management, or otherwise. In this context, "control" means the ability to replace the officers or directors or otherwise materially influence or control management decisions. Our Affiliates are entitled to enjoy our rights under this Privacy Policy and we will be responsible for our Affiliate's conduct related thereto.
Regulators: We may share information about you with U.S., state, or international regulators, including the SEC or FINRA, where we believe doing so is required or appropriate to comply with any laws, regulations, or other legal processes or law enforcement requests, such as court orders, search warrants, or subpoenas, including the requirements under the Federal Stored Communications Act ("SCA"), 18 U.S.C. Sections 2701-2712.
Third-Party Sites: The Platform may contain links to third-party websites and may redirect you to third party websites. These sites include, among others, service providers who have a relationship with Ocean Shore Capital. Third-party websites are not under our control, and we are not responsible for any third-party websites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes, or updates. The inclusion of links or access to these websites does not imply an endorsement by Ocean Shore Capital, or of the provider of such content or services, or of any third-party website. Please be aware that when you visit a third-party website, any information you provide, including financial information, is subject to the terms of use and privacy policy of that website.

How We Safeguard Your Personal Data

Security Systems and Processes: Ocean Shore Capital has developed a detailed written Information Security Policy that covers all Ocean Shore Capital personnel, and regularly conducts company-wide training on protecting the personal information of our clients and investors, as well as the disposal of non-essential customer information. We have put in place security systems designed to prevent unauthorized access to or disclosure of Personal Data, and we take all reasonable steps to secure and safeguard this Information, including:

Our Platform's password-protected section requires users to give us unique identifiers such as their user ID and password and authenticate themselves prior to accessing the Services;
We use industry-standard encryption technology for any information we store:
Ocean Shore Capital employees are required to acknowledge that they understand and will abide by this Privacy Policy with respect to the confidentiality of Personal Data;
Where applicable, companies that we do business with agree to abide by this Privacy Policy and apply similar safeguards regarding Personal Data;
We provide access to our databases containing Personal Data to Ocean Shore Capital’ employees, companies and vendors we do business with, and, if and when applicable, government regulators on a need-to-know basis only; and
We use automated tools to monitor network traffic to detect, identify and track unauthorized attempts to upload information, change information, or otherwise seek to "hack into" our systems.

Our security systems are therefore structured to deter and prevent hackers and others from accessing information you provide to us. However, please understand that this information should not be construed as a warranty that our security systems are fail proof. Due to the nature of internet communications and evolving technologies, we disclaim and cannot provide assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

Credit Card Security: Ocean Shore Capital does not take or retain credit card information directly. Any credit card information submitted will be collected and processed through our third party financial providers and will be governed by their terms and conditions and privacy policies.

Other Important Privacy Information

Opting Out of Communications:

If you wish to stop receiving marketing or promotional communications or to opt out of the use of your information for the purposes described in this policy, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You can also contact us at here to opt out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our Terms of Use or this Privacy Policy. Please understand that you will not be allowed to opt–out of certain communications required to comply with applicable laws, rules, or regulations, or other legal and related notices concerning your relationship to the Platform use of the Service.

Changing or Deleting Information:

You may review, update, correct, or delete your Personal Data that Ocean Shore Capital has on file by contacting us at here or, in certain cases, by accessing your member account. If you request, we will take reasonable steps to remove your name and other Personal Data from our databases. Please understand, however, that:

it may be impossible to remove this information completely, due to IRS and regulatory reporting requirements, your investments on the Platform and your related rights, and our data backups and records of deletions;
if you request deletion of your Personal Data, you may be unable to use certain features of the Platform and any associated Service; and
certain Personal Data may remain in our databases following the deletion of your account pursuant to our data retention policy.

Incident Response:

In the event of a purported data breach or inclusion of Personal Data in information accessed from the Platform without your consent, we will investigate and endeavor to notify any affected individual in writing (including by email) within seventy-two (72) hours of the breach or inclusion. This notice will provide, at a minimum, a description of the event, the type(s) of information that was affected, Ocean Shore Capital’ mitigation response, and information for any individual on how to further protect the individual’s Personal Data.

Data Retention:

We retain information we collect for as long as you use the Services (including your ownership of securities in Ocean Shore Capital entities) or as necessary to fulfill the purposes for which it was collected, provide our Service, resolve disputes, establish legal defenses, enforce our agreements and comply with applicable laws. We may retain information in anonymized and aggregated form that is otherwise deleted, in archived or backup copies as required pursuant to our records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Lost or Stolen Information:

You must promptly notify us if you become aware that any information provided by or submitted to the Platform is lost, stolen or used without permission.

Right to Opt Out of Sharing:

You have the right to request to opt out from your Personal Data being shared with unaffiliated third parties of Ocean Shore Capital through a “”Do Not Sell” request by contacting us here here. Please note that you may not be able to opt out if the Personal Data is shared: (i) pursuant to a joint marketing arrangement with third-party service providers (if disclosed to you); (ii) in connection with maintaining and servicing customer accounts and effecting certain transactions; or (iii) in situations related to protecting against fraud, complying with certain legal and regulatory requirements, and required consumer reporting.

Download or Access Your Personal Data on File:‍

You can ask us for a copy of your Personal Data, including a copy in machine readable form, by contacting us here.

Children and Teens:

In compliance with federal law, including the Children's Online Privacy Protection Act, WE DO NOT ALLOW INDIVIDUALS WHOM WE KNOW ARE UNDER 18 YEARS OLD TO PARTICIPATE IN OUR PLATFORM OR SERVICE. YOU MUST BE AT LEAST 18 YEARS OLD TO USE OUR PLATFORM AND SERVICE. Please understand that we cannot necessarily tell if a user provides us with his or her true age. If a parent or guardian becomes aware that his or her child has provided us with information without the parent or guardian’s consent, he or she should contact us at here. We will delete such information from our files within a reasonable amount of time.

Changes to this Privacy Policy:

Each time you visit our Platform or use our Service, the current version of this Privacy Policy will apply. Whenever you use our Platform or Service, you should check the date of the last update to the Privacy Policy (which appears at the top of the policy) and review any changes since the last version. Our business changes frequently, and this policy is subject to change from time to time. Unless stated otherwise, our current Private Policy applies to all information that we have about you. We may require you to affirmatively consent to a revised version of the Privacy Policy as a condition of continuing to use the Platform and/or our Service.

Further Resources:

If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the FTC's website.

We Operate in the United States:

Ocean Shore Capital is based in the United States. The Service is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Service, you consent to: (i) the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country; and (ii) the use of your Personal Data in accordance with this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.

European Economic Area Residents

If you are an individual residing in the European Economic Area (“EEA”), we collect and process information about you only where we have a legal basis for doing so under applicable EU laws, including the European General Data Protection Regulation 2016/679 (“GDPR”). The legal basis depends on the particular Service you use and how you use it. This means we collect and use your information only where:

We need it to provide you the Service, including to operate the Service; perform a contract with you, take necessary steps prior to performing a contract, or at your request, provide customer support; and protect the safety and security of the Platform and the Service; or
It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Service, to personalize a Service you receive, and to protect our legal rights and interests.

You give us consent to do so for a specific purpose; or we need to process your data to comply with a legal requirement. If you have consented to our use of information about you for a specific purpose, you may change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you may object to that use though, in some cases, this may mean no longer using the Services. To do so, please contact us here.

As detailed above, in the event of a data breach, we will endeavor to notify you within seventy-two (72) hours of detection of a breach that we conclude poses significant risks to your rights and freedoms under the GDPR. You may also lodge a complaint with a supervisor authority in the EEA member state in which you reside.

For the purposes of the GDPR, the Ocean Shore Capital company from which you have purchased products and/or services, or with which you have entered into communications, or which has otherwise collected your Personal Information is the controller of your Personal Information.

California Residents

Pursuant to the California Consumer Privacy Act (“CCPA”), residents of California have certain rights concerning a business with which the California resident has an established business relationship regarding the Personal Data the business collects, uses, and discloses. For example, California residents have the right to know what Personal Data a business has about them. California residents can obtain a report of this Personal Data once every twelve (12) months.

When California residents terminate their accounts on the Platform, they have the right to have their information forgotten (i.e., deleted), except to the extent the Platform is prohibited by law from deleting the information.

California residents also have the right to opt out from their data being sold or otherwise monetized with third parties through a “Do Not Sell” request.

To request your Personal Data information, exercise your right to request deletion, or exercise your Do Not Sell request, please contact us by email at here.

If you have any questions about this Privacy Policy, this Platform or the Service, or your interactions with the Platform or Service, please contact us by e-mail as follows: here.

You may also contact us by phone at or by mail at: Office No.12 On 19th Floor, Ho King Commercial Centre, No.2-16 Fa Yuen Street, Mongkok, Kowloon, Hong Kong.

Effective Date: November 17, 2023

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