Privacy policy

Welcome to the Loci Platform (“the Platform” or “Website” or “GetLoci”), the venue used to self-direct Loci Assets by principals of the Loci Program. This is a Privacy Policy between principals of the Loci Program, including you, a Lender, or any successor (“Holder”), and the Company, the Loci Program borrower, Connect Financial, Inc., (also “Maker” or “Borrower” or “CFI”), and Rivers Connect Foundation the Loci Program owner (“Owner” or “RCF” and together with Maker “we” or “us”).

We value your privacy. The following policies apply to the collection of data by the Company and affiliates. If you have questions or concerns regarding this statement, you should first contact us at notices@loci-mail.com.

To assist your self-directed use of GetLoci, and to ensure a clear understanding of the relationship arising from your participation in the Loci Platform and its mutual asset exchange, we have created this privacy policy ("Privacy Policy" or "Policy") and the Use Agreement ("Use Agreement" or "Usage Terms"). The Usage Terms govern your use of GetLoci. This Policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any personal or personally identifiable information that we may request will be used. Furthermore, we detail our security policy, which describes how your personal information is protected.


The Privacy Policy and Usage Terms apply to anyone who accesses and/or uses GetLoci, including:

  1. Casual visitors, who do not participate in the Loci Platform or the Peer Markets, and

  2. Users who register for, access, and/or use GetLoci (referred to singly as a "User," or "you" and collectively as the "Users" or "you").

By accessing or using GetLoci at www.getloci.com, including any subdomain thereof, you signify that you have read, understood, and agreed to be bound by the Use Agreement and the Privacy Policy.


The content of the pages of this Website may change without notice from time to time, including but not limited to this Privacy Policy. You understand and agree that your continued access to or use of the Website after we have made any such changes constitutes your acceptance of the new Privacy Policy.


We collect personal and financial information from you while you use GetLoci; most of this collection occurs during registration. Most of the information collected is required for legal or security purposes, although some is optional. Additional information may be gathered during your subsequent use of GetLoci, whenever you choose to provide it; however, in order to use certain features, you must provide certain information.

In general we collect several types of information from you:

a. Personal data required to verify your identity and create your profile (“User Profile”);

b. Personal and financial data necessary to assess your eligibility to participate in the Loci Platform and the Peer Markets;

c. Information about your visits to and use of this Website to help us maintain the appropriate features, functionality, and User experience.

Certain personal information must be supplied during the User registration process, as indicated below, in order to:

a. Enable you to log in to the Website;

b. Establish your ability to view offering materials and to participate in the Loci Platform and the Peer Markets;

c. Verify that you are at least 18 (eighteen) years of age;

d. Guard against potential fraud;

e. Contact you if there is a problem with your User Profile;

f. Maintain regular communications with you as may be necessary to inform you of upcoming features, investment opportunities, and other updates.

This basic personal information includes your name, country of residence, email address, and preferred language.

Prior to gaining access to further features in GetLoci, you will be directed to provide additional data, such as your date of birth, home address, mailing address, profession or activity, Social Security number, accreditation status as defined in Rule 501 of Regulation D of the Securities Act of 1933, as amended (US residents only), and, in certain instances, a preferred bank routing number and bank account number.

This data is needed to determine eligibility and to enable funds transfers and investment disbursements to you.

In addition, we gather names and email addresses of people who contact us through the Website with questions about the Company, CFI, or GetLoci. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people, as in the case of job applicants who submit resumes.

Finally, we collect information about your computer and your visits to the Website, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We use this aggregated information in the administration of GetLoci to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies, and other marketing activities. We use non-identifying and aggregated information to help optimize GetLoci based on the needs of Users.


We will send you email notifications from time to time. Such notifications are required elements of your transactions in GetLoci, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status such as when you are confirmed as a User, or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that another person cannot make a change to your User Profile without your knowledge. In other cases, these notifications involve changes to various legal agreements or policies. Generally, you may not opt out of such service-related emails.

When you register as a User, you may receive emails that confirm specific actions you requested; these will include emails to which you must respond to complete your registration, and notifications confirming your registration. Thereafter, you may receive emails when a new investment opportunity is offered, as well as updates concerning the progress of the funding of such opportunity or offering other relevant information. We may also send you responses to emails you send us, if appropriate. From time to time, we may also send User surveys, requests for User feedback regarding User experience and GetLoci operations, or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys, or User feedback emails, please opt out in any offer email you receive from us.


The Company does not sell or rent personal information about Users for marketing purposes. We do, however, work with a number of trusted partners who perform vital functions as part of our operations.

In addition to our affiliates, we also work with (among others) providers of hosting services for the Website, escrow agents, and trust service providers. We may engage third parties to help us to carry out certain other internal functions such as User registration processing, client services, or other data collection relevant to our business; examples of such companies might include companies that perform data processing, reporting, tax documentation, custody, or escrow services. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or to perform other specific services, such as collections. Our partners are legally required to keep your information private and secure.

Your Profile information may, in a generic way, be made publicly available for use on the "Statistics" page of the Website or in other summaries of aggregated investment data.

We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of GetLoci, or to protect the rights, property, or personal safety of GetLoci, its Users, issuers, or others.


We urge you to review your information regularly to ensure that it is correct and complete. If you believe that any of your information is incorrect, or if you have any questions regarding this Privacy Policy, please contact us at notices@loci-mail.com.


When you visit the Website, whether or not you register as a User, we may send one or more “cookies” – small text files containing a string of alphanumeric characters – to your computer. These small text files may be placed on your web browser, where they will store information on your computer such as your preferences when visiting the Website. We use cookies when you sign in, and to keep track of your personal session, including some User Profile identifiers so that we can ensure that you are the only person making changes to your User Profile. We also use cookies to track your activity on GetLoci as a unique person. All of this information is stored in an encrypted fashion for security reasons, and no personal information about you is stored. You can set your web browser to inform you when cookies are set or to prevent cookies from being set. Please note, however, that if you decline to use cookies, you may experience reduced functionality and slower site response times; your declining to use our authentication-related cookies may prevent you from using the Website altogether.

We (or our service providers, such as Google Analytics) may also collect web surfing data related to your use of GetLoci. This may include, for example, information regarding which of our web pages you access, the frequency of such access, and your product preferences. This data collection may be accomplished by using cookies, web beacons, page tags, or similar tools that are set when you visit the Website. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, and operating system, as well as the dates and times that you visited the Website. Web surfing data and similar information may be used for administrative purposes, to assess the usage, value, and performance of our online products and features, and to improve your experience with GetLoci. As with cookies, the web surfing information collected is aggregated, anonymous "click stream" and transactional data, and is not associated with any Users as individuals.


If you follow any links that direct you away from the Website, this privacy policy will not apply to your activity on the other websites you visit. We do not control the privacy policies or the privacy practices of any third parties.


GetLoci may be accessed by Users located outside the United States. If you choose to use GetLoci from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States, and that by providing your personal information on or through the Website then you consent to that transfer.


We limit access to the personal information we have about you to those employees who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. [The Website is built upon a secure infrastructure with multiple layers of protection and we use industry standard encryption technologies to safeguard your information.]

Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Website. Generally, identification and authentication take place through the use of your User name and password and/or while logging in with one of our technical support staff.

If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Website in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

You can take several precautions to protect the security of your computer and personal information. For instance, you can use a well-chosen password, and restrict access to your User Profile. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on the Website, be sure that you log out and close the browser window.

You should also be aware of fraudulent attempts to gain access to your User Profile information known as "phishing," whereby scammers try to bring unsuspecting people to a website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on this fake site, scammers will ask for login information to gain access to people's User Profiles and withdraw their money.

The Company will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go to the Website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain. In the case of the Company, you should always ensure the URL begins with https://www.getloci.com or https://getloci.com.


The Effective Date of this Privacy Policy is August 1, 2020.