T12™
Privacy Policy

Privacy Policy

Effective date: September 5, 2024

This privacy policy (“Privacy Policy”) applies to TWO12 Inc. (“Company” or “T12”), and its online tools and platform(s), including www.T12.ai and other T12 websites (collectively, the “Services”) and other interactions (e.g., customer service inquiries, user conferences) you may have with the Company. Except as otherwise indicated, this Privacy Policy describes how T12 collects, uses, and shares your personal information and your choices with respect to your personal information.

California residents: Please see the important information in our Notice for California Residents

What we collect

We get information about you in a range of ways:

Information You Give Us

For customers who have paid software services, we collect your billing details such as credit card information, banking information, and/or billing address.

We also collect your name, username, and password.

We may collect your‎ postal address, email address, phone number, social security number, tax ID number, demographic information, as well as other information you directly give us on our Services.

Information We Get From Others

We may get information about you from other sources, such as your employer when they issue you options or shares. We may add this to information you provide us through our Services.

Information Automatically Collected

Device Information

We may collect information about the devices accessing our Services. Some examples are: type of device, operating system used, application information, unique device identifiers and crash data. The type of information we collect depends on the type of device used and its settings.

Transactional and Usage Information

We may automatically log information about you and your computer, subject to your consent where required by law. For example, like most services when using our Services, we log your computer operating system type, browser type, browser language, pages or screens you viewed, how long you spent on a page or screen, location (your IP address), access times and information about your use of and actions on our Services. This is information we collect from every user of the Services, whether they have an account or not. This information may include personal information.

Use and disclosure of personal information

We may use, process and/or disclose personal information for the following purposes:

• To operate, maintain, and improve the Services. This includes use of other information to support delivery of our services, assist with service requests, monitor for errors, remedy security or technical issues, analyze website and application performances.
• To respond to comments and questions, verify permission access, and provide customer service.
• To send information including confirmations, invoices and billing, technical notices, updates, security alerts, and administrative messages.
• To communicate upcoming events and other news about products and services offered by us.
• To communicate and inform you about system updates and important services-related notices, such as privacy and policy update notices or changes in our terms of service. These communications are administrative and you may not opt out of them.
• To send marketing emails related to the Services, which you may opt out of using provided unsubscribe links or the opt-out mechanism in those communications.
• To link or combine user information with other personal information. An example is when we combine the information a company has provided about their shareholders with the information entered by shareholders in their personal portfolios to improve the user experience.
• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity, including, but not limited to, validating your identity and preventing fraud on your account, and complying with KYC rules and regulations.
• To provide and deliver products and services to our business customers with respect to their employees or investors. An example is when an employee exercises their employee stock options and we provide a tax form to their employer to facilitate compliance with tax laws.
• To facilitate online advertising. Third-party advertising companies and social media companies may use cookies and similar technologies to collect information about your interaction over time across the Services, our communications and other online services, and use that information to serve online ads that they think will interest you.

We may also use and disclose personal information as follows:

• Our business customers’ equity administrators, authorized users and other designated representatives can access information that we hold about the equity information of their employees and investors.
• To comply with laws, lawful requests and legal or regulatory processes.
• To protect the rights, safety and property of T12, our agents, users, customers, and others. This includes enforcing our agreements, policies, and terms of use, reporting on security breaches, or assisting with investigating and preventing fraud or security issues.

We may create, use and share aggregated or anonymized data for any lawful purpose, such as marketing, analytics or research purposes permitted by law.

We may share personal information with acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, T12 (including, in connection with a bankruptcy or similar proceedings).

We may share other information with third parties in other ways not described in this Privacy Policy when we have consent (either from users or business customers) to do so.

We may share personal information with third party companies or individuals that we engage as service providers to process information and support our business and services. Examples include providers of cloud hosting and storage services, analytics, services, email delivery services and customer support services.

We may share personal information with our lawyers, accountants and other professional advisors in the course of the services they render to us.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Age Limitations

T12 does not allow the use of our Services by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data through the Services, please contact us and we will take steps to delete such information.

Information choices and changes

Our marketing emails tell you how to “opt out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you. If at any time you would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism in those communications for your convenience.

You may send requests about personal information to support@t12.ai. You can request to change contact choices, opt out of our sharing with others, and update your personal information.

You can typically remove and reject cookies from our website with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it may affect how our website works for you.

You can update or correct certain personal information in your T12 account. If you are unable to do so on your own, the information is likely controlled by the security issuer and you should contact the security issuer directly to update your information.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

Notice for California Residents

Scope.  This section applies only to California residents.  It describes how we collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information.  For purposes of this section, “Personal Information” has the meaning given in the CCPA.  However, this section does not apply to:

• Information exempted from the scope of the CCPA, including nonpublic personal information;
• Personal Information we collect from individuals acting in their capacities as representatives of organizations solely in the context of conducting due diligence regarding, or providing or receiving a product or service to or from, such organizations; and
• Personal Information we collect, use, and share on behalf of our customers as a “service provider” under the CCPA for purposes of providing our services to them.

T12 does not sell (as such term is defined in the CCPA) the Personal Information we collect (and will not sell it without providing a right to opt out).

Your California privacy rights. You have the following rights under the CCPA

• Information.  To request the following information about how we have collected and used your Personal Information during the past 12 months:
• The categories of Personal Information that we have collected.
• The categories of sources from which we collected Personal Information.
• The business or commercial purpose for collecting Personal Information.
• The categories of third parties with whom we share Personal Information.

• Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information disclosed to each category of third party recipient.
• Access.  To request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion.  To request that we delete the Personal Information that we have collected from you.
• Nondiscrimination.  To exercise the rights described above free from discrimination as provided in the CCPA.

How to exercise your rights. You may submit requests to exercise your right to information, access or deletion by submitting your request via email to support@T12.ai. We will need to verify your identity to process your information, access and deletion requests and we reserve the right to confirm your California residency. You may be required to provide government identification, give a declaration as to your identity under penalty of perjury and/or provide additional information. If you wish to designate an authorized agent to make a request on your behalf, we will need to verify both your and your agent’s identities and your agent must provide a valid power of attorney pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain cases, we may be required or permitted by law to deny your request.

Personal information that we collect, use and disclose. For each category of data described above in the “What we collect” section of the Privacy Policy, the list below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA, and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Services.  Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.