DISCLAIMER: NOTHING CONTAINED HEREIN SHOULD BE TAKEN AS AN OFFER TO SELL SECURITIES OR THE SOLICITATION OF AN OFFER TO PURCHASE SECURITIES. ANY OFFER OF SECURITIES IN ANY PROJECT MAY ONLY BE MADE PURSUANT TO A WRITTEN OFFERING MEMORANDUM AND ANY SALE OF SECURITIES IN SUCH PROJECT SHALL BE EVIDENCED BY A SUBSCRIPTION AGREEMENT EXECUTED BY THE POTENTIAL INVESTOR. IF THE INVESTOR IS A U.S. PERSON RESIDING IN THE U.S. AT THE TIME OF THE OFFERING, THE OFFERING WILL BE MADE ONLY TO “ACCREDITED INVESTORS,” AS DEFINED UNDER RULE 501(A) OF REGULATION D OF THE SECURITIES ACT OF THE U.S. IF, AT THE TIME OF THE OFFERING, THE INVESTOR IS A NON-U.S. PERSON AND IS NOT LOCATED IN THE U.S. THEN REGULATION S OF THE 1933 SECURITIES ACT SHALL APPLY. IRRESPECTIVE OF JURISDICTION, NO OFFER TO SELL OR SOLICITATION OF AN OFFER TO BUY SECURITIES MAY BE MADE TO ANY PERSON TO WHOM IT IS UNLAWFUL TO MAKE SUCH AN OFFER OR SALE
Updated May 25, 2018
Your privacy is critically important to us. At Ellis Island Capital, we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information for only as long as we have a reason to keep it.
- We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
- We help protect you from overreaching government demands for your personal information.
- We aim for full transparency on how we gather, use, and share your personal information.
Who We Are and What This Policy Covers
Howdy! We are the folks who help you get from any country in the world to the US by means of EB-5.
- com and Ellisislandcapital.net
- Our mobile applications (including the WordPress mobile app for Android and iOS);
- Our other products and services that are available on or through our websites (including WordPress.com, Crazy Egg and Paypal)
- Other users’ websites that use our Services, while you are logged in to your account with us.
Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Information We Collect
We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better.
We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
- Basic Account Information:We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a WordPress.com account to provide a username and email address–and that’s it. You may provide us with more information–like your name–but we don’t require that information to create a WordPress.com account.
- Public Profile Information:If you have an account with us, we collect the information that you provide for your public profile. For example, if you have a WordPress.com account, your username is part of that public profile, along with any other information you put into your public profile, such as a photo or an “About Me” description. Your public profile information is just that–public–so please keep that in mind when deciding what information, you would like to include.
- Transaction and Billing Information:If you buy something from us–a subscription to a WordPress.com plan, a premium theme, or a custom domain, for example–you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.
- Content Information:Depending on the Services you use, you may also provide us with information about you.
- Communications with Us (Hi There!):You may also provide us information when you respond to surveys, communicate with our sales people or customer service personnel about a support question, or post a question about your VISA or progress in our public forums.
Information We Collect Automatically
We also collect some information automatically:
- Log Information:Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services–for example, when you create or make changes to your website on WordPress.com.
- Usage Information:We collect information about your usage of our Services. For example, we collect information about the actions that site administrators and users perform on a site using our WordPress.com or Jetpack services–in other words, who did what, when and to what thing on a site. We also collect information about what happens when you use our Services (e.g., page views, support document searches at en.support.wordpress.com, features enabled for your website, interactions with our customer service people and other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
- Location Information:We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (when, for example, you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
- Stored Information:We may access information stored on your mobile device via WhatsApp
- Interactions with Other Users’ Sites:We collect some information about your interactions with other users’ sites while you are logged in to your account with us, such as your “Likes” and the fact that you commented on a particular post, so that we can, for example, recommend posts we think may interest you. As another example, for Intense Debate users, we collect information about the comments you make while logged in to your account, and use that information to, for example, tally up statistics about your comments (check them out in your dashboard!) and provide the information about your comments in your Intense Debate public profile.
Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you create or log into your WordPress.com account through another service (like Google) or if you connect your website or account to a social media service (like Facebook), we will receive information from that service (such as your username, basic profile information, and friends list) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available.
How and Why We Use Information
Purposes for Using Information
We use information about you as mentioned above and for the purposes listed below:
- To further develop and improve our Services–for example by adding new features that we think our users will enjoy or will help them to create and manage their websites more efficiently;
- To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
- To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition–for example, we may analyze how many individuals purchased a plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;
- To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Ellis Island Capital and others, which may result in us declining a transaction or the use of our Services;
- To communicate with you, for example through an email, about offers and promotions offered by Ellis Island Capital and others we think will be of interest to you, solicit your feedback, or keep you up to date on Ellis Island Capital and our services; and
- To personalize your experience using our Services, provide content recommendations, target our marketing messages to groups of our users and serve relevant advertisements.
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account–for example, in order to enable access to our website on your device or charge you for a paid service; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information–for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or
How We Share Information
We do not sell our users’ private personal information.
We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
- Third Party Vendors:We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you. This group includes attorneys and project managers where you might be investing in order to obtain your EB-5 Green cards.
- To Protect Rights, Property, and Others:We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Ellis Island Capital, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- With Your Consent:We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so, such as attorneys assisting you in sourcing funds or filing an application.
- Aggregated or De-Identified Information:We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services and we may share a hashed version of your email address to facilitate customized ad campaigns.
- Published Support Requests:And if you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to publish that request in order to help us clarify or respond to your request or to help us support other users.
How Long We Keep Information
We generally discard information about you when we no longer need the information for the purposes for which we collect and use it–which are described in the section above on How and Why We Use Information–and we are not legally required to continue to keep it.
For example, we keep the web server logs that record information about a visitor to one of Ellis Island Capital’s websites, such as the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to Ellis Island Capital’s websites and investigate issues if something goes wrong on one of our websites.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.
To enhance the security of your account, we encourage you to enable our advanced security settings, like Two Step Authentication.
You have several choices available when it comes to information about you:
- Limit the Information that You Provide:If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services–for example, paid, premium themes–may not be accessible.
- Limit Access to Information on Your Mobile Device:Your mobile device operating system should provide you with the ability to discontinue our ability to collect stored information or location information via our mobile apps. If you do so, you may not be able to use certain features like WhatsApp to chat with us.
- Opt-Out of Electronic Communications:You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.
- Set Your Browser to Reject Cookies:At this time, Ellis Island Capital does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Ellis Island Capital’s websites, with the drawback that certain features of Ellis Island Capital’s websites may not function properly without the aid of cookies.
- Close Your Account:While we’d be very sad to see you go, if you no longer want to use our Services, you can close your account with us. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above–for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
EU individuals also have the right to make a complaint to a government supervisory authority if we don’t respond to any of your requests.
How to Reach Us
Other Things You Should Know (Keep Reading!)
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
Ads and Analytics Services Provided by Others
Terms of Service
Updated May 25, 2018
Terms of Service:
We use the term “Designated Countries” to refer to Australia, Canada, Japan, Mexico, New Zealand, and all countries located in the European continent. If you reside in the “Designated Countries,” your agreement is with:
Ellis Island Holdings Limited, Suite 6 Mill Mall P.O. Box 3085 Wickhams Cay1 Road Town Tortola British Virgin Islands, Tortola, Virgin Islands (British)
If you reside outside of the “Designated Countries,” your agreement is with Ellis Island Capital, Inc.
Please read this Agreement carefully before accessing or using our Services. By accessing or using any part of our Services, you agree to become bound by the Terms of this Agreement. If you do not agree to all the Terms of this Agreement, then you may not access or use any of our Services. If these Terms are considered an offer by Ellis Island Capital, acceptance is expressly limited to these Terms.
Our Services are not directed to children. Access to and use of our Services is only for those over the age of 13 (or 16 in the European Union). If you are younger than this, you may not register for or use our Services. Any person who registers as a user or provides their personal information to our Services represents that they are 13 years of age or older (16 years or older in the European Union).
Use of our Services requires opting in to one of our offers and receiving information, messaging and WhatsApp communications on a regular basis and all communications are restricted to permanent green cards in the US and the process required to do so. You agree to provide us with complete and accurate information when you register for an account. You will be solely responsible and liable for any activity that occurs under your username.
That’s it! Thanks for reading.