Privacy Policy

Effective September 26, 2025
This privacy policy (“Privacy Policy”) describes how SMB VIG LLC, any special purpose vehicle(s) for investments, as well as SMB VIG LLC (“SMB VIG” “we” “us” or “our”) collect, use, and share information about users of our websites, including SMBVIG.com, our Apps and our associated services (collectively, our “Site” and “Services”). We are committed to protecting and respecting your privacy. To understand more about the roles, we carry out in handling personal information, please see the Contact Us section. By using our Site and Services, you acknowledge you have read and understood this Privacy Policy and our practices described below. Your use of our Site and Services is also subject to our Terms of Use. Please note that any user information shared with one of our entities may be shared among the other SMB VIG entities. Please review SMB VIG’s Privacy Notice for a summary of our practices regarding the personally identifiable financial information we collect about you in connection with our services.

Information We Collect about you

Information you provide us.

When you use our Site, our Services or otherwise choose to interact with us, we receive personal information about you such as when you register for and create a profile on our Site. Personal information means information from which you may be identified both directly (from that information alone) and indirectly (when different pieces of information are combined).

We may collect and process the following personal information from you:

Name and contact. This information may include your name, address phone number, email address, social media handle that you provide if you fill in forms on our Site or otherwise contact us.
Account login details. If you choose to sign up and create an account, we will collect your name, chosen username and password.
Account profile details. On your SMB VIG profile, you can make additional optional personal details available including a photo, biography, links to a personal website or blog, details of your skills, investment goals and interests, and other similar information.
Identity details. We may need to collect certain information to verify your identity, including your name, date of birth, applicable tax or other national issued identifiers, Social Security number, and /or other legally recognized identity documentation such as your driver’s license.
Investor details. To ensure compliance with legal requirements, we may need to collect your net worth, income and other information necessary to verify your investor accreditation or sophistication status.
Investment transaction details. If you choose to invest in an offering through our Site, we will collect payment information from you, such as financial account information or payment card information, and we may collect information to verify your income, such as a bank statement or W-2 form. Please note that we do not store your payment card information, but we do store other financial information. If you choose to add an investment entity to your Account profile, we will also collect information about the entity.
Founder business details. If you would like to raise funding for your business with our Site and Services, we will collect information about your business, including other officers and stockholders, business financial statements, your fundraising terms, and payment and banking information.
Compliance information. We may need to request information in connection with business legal and regulatory risk checks.

We also collect information when you post questions or comments on our Site, send or receive direct messages from other users or when you contact us, including via email, or social media.

We will indicate whether information is required or voluntary on the Site

When you visit our Website.

We may automatically collect certain information when you use our Site including:

- Interaction information about your use of our Site, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site including the actions you take, the pages or other content you view, search for or otherwise interact with, content response times, and the dates and times of your visits.
- Technical and device information, such as you IP address used to connect your device to the internet, operating system information and web browser and /or device type, version and time zone setting and language.
- Location information, we may derive your regional location from your IP address.
- Cookies and similar technologies, When you visit our Site, we and our service providers collect certain information through the use of “cookies” and other similar technologies to better understand how our users navigate through our Site, learn what content is being viewed and administer and improve our Site and Services. Cookies are small text files that web servers place on an internet user’s device that are designed to store basic information and recognize your browser. We use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Site. We use cookies /and other similar technologies either alone or in combination with each other to create a unique ID which corresponds to you. For more information see the ‘Use of cookies and other technologies’ section below.

Information from other sources.

Social Media, If you make your personal information publicly available, such as information posted to social media sites when you tag us, or otherwise interact with our social media channels and posts, for example by liking a post, we may collect personal information such as your social media profile name and picture or content you post, like and reactions to your posts.

How we use Information we Collect

We may use the information we collect for the following purposes:

Information you provide us.

To take steps to enter into any contract or carry out obligations arising out of our terms with you including to:
- administer your account with us
- process payments and investments
- notify you about changes to our Services
- keep a record of transactions
To comply with legal obligations to which we are subject including:
- identity and/or business verification checks
- record keeping requirements
- cooperating with regulatory authorities
Where necessary in our legitimate interests
- In providing the information you request from us, including responding to any queries you have submitted
- in managing corporate risk, security and compliance operations
- to enforce this Privacy Policy or other terms to which you have agreed, and to protect the rights, property or safety of us, our Site our users, or any other person.
With your consent, where required, for example to send you our marketing communications.
Unless we are required to obtain your consent, we will use this information in our legitimate interests where we have considered these are not overridden by your rights to:
- provide, improve and personalize our Site
- monitor and analyze usage trends and preferences
- keep our Site and Services safe and secure
- measure or understand the effectiveness of our communications or advertising to you and others and to deliver relevant advertising to you

Information from other sources

Unless we are required to obtain your consent, we will use this information in our legitimate interests where we have considered these are not overridden by your rights:
- We may use information obtained via social media channels for our own analysis and marketing purposes.

Use of Cookies and other Technologies

Necessary Cookies

Intercom – we use intercom so that users of our Site can communicate with our customer support team via our live chat function
Stripe – we use Stripe to handle payment processing. Stripe uses cookies to authenticate users and protect against fraud.
Vitesse – we use Vitesse to handle payment processing. Vitesse may use cookies to authenticate users and protect against fraud.
Plaid – We use Plaid to connect and verify banks accounts.
Sift – We use Sift to help us detect spam and fraud.
SMB VIG First Party Cookies – We use these cookies for user login.
Cloudflare – We use this for attack and spam prevention.

Analytics cookies

Google Analytics cookies enable us to recognize and count the number of visitors and to see how they engage with our Site content and features. This helps us for our legitimate interests of improving the way our Site works, in order to provide you with the most relevant content. For example, ensuring that users are finding what they are looking for easily. You can find more information on how Google uses data from these cookies including about how to opt-out at the below links:
https://google.com/policies/privacy/partners/.https://tools.google.com/dlpage/gaoptout
Google advertising cookies are used to show you our ads on other websites across the Internet. These ads may be directed to you based on your past visits to our Site and your use of our Site. You can find more information on how Google uses data from these cookies including about how to opt-out at the below links:
https://google.com/policies/privacy/partners/.https://adsettings.google.com/

Social networking cookies

These cookies help us to manage our social media, including enabling you to share content and enabling us to understand how you interact with us.

Facebook – we use Facebook cookies and pixels to help deliver our advertising on Facebook. This means you may see our ads when you use Facebook because you have visited and then visited Facebook. These cookies also tell us if you come to our Site after having clicked on an advertisement on Facebook. We also work with Facebook to deliver our ads to Facebook users who match against certain criteria which Facebook identify. Please visit your Facebook privacy settings to learn more and see here: https://facebook.com/policy.php
X.com – we use X.com cookies to deliver our ads on the X.com platform to you and to those other X.com users who might be interested in our Services based on their online activities including on the X.com platform. Please visit your own X.com privacy settings to configure how ads are displayed to you.

You can opt out of our service provider’s use of cookies for directed marketing purposes by visiting the US Network Advertising Initiative’s opt-out page at https://optout.networkadvertising.org/, the Digital Advertising Alliance’s consumer choice tool at https://optout.aboutads.info or in Europe the European Interactive Digital Advertising Alliance (EDAA) program at https://youronlinechoices.eu/. Please note that after opting out, you may continue to see ads from those service providers, but they will not be based on your past activities.

You may choose to disable some cookies. The effect of disabling cookies depends on which cookies you disable. Please note that if you delete, or choose not to accept, all cookies from our Site, you may not be able to utilize certain features of our Site to their fullest potential. You can also consult your web browser settings to learn the proper way to modify cookie settings.

How We Share Information We Collect

We may make information available to:

Businesses You Invest In.

We may share your information with businesses that you invest in. The information about you that we share with the business you invest in may include your public profile information and your address, email address and tax/national issued identifier or Social Security number including for compliance, tax and accounting purposes.

Other Users and the Public.

Please note that your profile page is viewable by other users and the public. For information on privacy settings available to you, please see the “Account Settings Choices” section below.
Any comments or information you submit or share on public areas of the Site, such as questions for founders, your bio, or a description of your business, can be read, collected or used by other users and the public. Please consider carefully the information you choose to submit or share on the public areas of our Site, such as investment pages or your public profile.
We also share your information with other users when you send or receive direct messages from other users.
Affiliates and Banks. In order to provide the services on our Site, we may share your information with other third parties, such as portfolio companies, investment banking firms, accountants and similar entities.
We use service providers to provide certain services to us and on our behalf and in accordance with our instructions. This includes in supporting our Services, in particular those providing Site data hosting services, fulfilment services, distributing any communications we send, fraud detection, facilitating feedback on our Services, advertising, marketing, analytics services and providing IT support services from time to time.
Payment processing providers who secure payment and bank transfer processing services. Note your payment card details are securely processed by the provider and not held by us.

We only provide our service providers and partners with information necessary for them to perform these services. Our analytics providers may collect information about your online activities over time and across different online services when you use our Site.

Change of control.

In the event that SMB VIG is merged or sold, or in the event of a transfer or sale of some or all of our assets, we may disclose or transfer information we collect in connection with the negotiation and/or conclusion of such a transaction.

Other disclosures.

We may disclose information about you to third parties if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies or terms of service, (c) to protect the security or integrity of our Site and Services, (d) to protect the property rights, and safety of us, our users, or the public, (e) to respond in an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations.

Your Account Settings Choices

You can update the information you provided to us by accessing your account settings. Through your account settings, you can also hide some portions of your profile from other users or the general public on the Internet as well as hide your profile from search engines that collect information from our Sites.

You can also opt out of promotional or marketing email communications, including affiliate marketing, by clicking on the unsubscribe link in any email you receive from us, by updating your communication preferences through your account settings on our Site, or by contacting us at support@SMBVIG.com

See also ‘Your Rights’ below.

Links to Other Websites

Our Site contains links to websites maintained by third parties. Please be aware that these third-party websites are governed by their own privacy policies and are not covered by our Privacy Policy. We are not responsible for the content or policies maintained by these websites. Please familiarize yourself with the privacy policy of any third-party websites you visit.

Security of Your Information

The security of your information is important to us. We have implemented security measures to help protect the information in our care. We make use of physical, electronic and organizational measures in an effort to safeguard and prevent unauthorized access.

All areas of our Site use SSH technology. Any payment transactions will be encrypted using SSL technology.
Where you have chosen a password which enables you to access certain parts of our Site and Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We take steps to limit access to your information only by those who need access.
We take steps to contractually require our service providers to protect any personal information they process on our behalf.

Unfortunately, the transmission of information via the internet is not 100% secure. Although we do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Children’s Privacy

Our Site is not intended for children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If we learn that we have collected the personal information from a child under the age of 13, we will take steps to delete the information. If you are aware that a child under 13 has provided us with personal information please contact us at privacy@SMBVIG.com.

International Data Transfers

Your personal information will processed in accordance with this policy in the U.S. and Europe. Where you are resident in Europe, we handle your personal information outside of the European Economic Area (EEA) and where we facilitate access to or transfer of your personal information outside of the EEA we will take steps to handle your personal information subject to appropriate safeguards, for example, implementing approved standard contractual clauses where appropriate as the laws regarding processing of personal information may be less stringent than the laws in the EEA.

Third parties that we work with may also process your personal information in the U.S. and/or facilitate the transfer of or access to your personal information outside of the U.S. We will take steps to require them to process your personal information subject to appropriate safeguards, for example, implementing standard contractual clauses where appropriate.

How Long we Keep your Information

We retain personal information:

for as long as we are legally required or otherwise permitted to meet our reason for collection (for example, for as long as we are providing Services to you) and as necessary after that to anticipate, resolve or defend any issues.
relating to any account or transactions with us, in order to meet our contractual obligations to you and and/or any transaction to identify any issues, resolve any legal proceedings and for tax and accounting purposes.

We may also retain aggregate information for research purposes and to help us develop and improve our services.

Your Rights

Depending on the country you access our Site and Services from, you may have the right under certain circumstances:

to find out what information we hold about you;
to be provided with a copy of your personal information;
to request the correction or deletion of your personal information;
to request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);
to object to the further processing of your personal information, including the right to object to marketing (as mentioned in ‘Your Account Settings Choices’ section);
to request that your provided personal information be moved to a third party.
You can un-install our App which will stop information being collected from the App. You may use the standard un-install processes as may be available for your mobile device.
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time.

If you wish to exercise any of the rights listed above that are available to you, you can do so at any time by contacting us and the data protection team will respond according to the applicable law.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.

The Dutch Data Protection Authority is the supervisory authority in the Netherlands in respect to SMB VIG and can provide further information about your rights and our obligations in relation to your personal information, as well as deal with any complaints that you have about our processing of your personal information.

Changes to Our Privacy Policy

Please revisit this page periodically to stay aware of any changes to our Privacy Policy, which we may update from time to time. If we modify our Privacy Policy, we will make it available on our Site and indicate the effective date.

In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access our Site for the first time after such material changes are made. Your continued use of our Site after the revised Privacy Policy has become effective indicates that you have read and understood the current version of our Privacy Policy.

Contacting Us

If I do not consent to receive the tax document electronically, a paper copy will be provided.
My consent continues for every tax year until I withdraw my consent.
I may log into My Account at SMBVIG.com to access and print my tax documents. I may need Adobe Acrobat Reader to open the document and a device connected to my computer that can print. In the event a tax document is too large to open in the browser, I will be prompted by a dialog box to save the file to a location on my computer and open it using Acrobat Reader.
To withdraw consent, I may email SMB VIG at support@SMBVIG.com to request to withdraw my consent.
If My Account is closed, my request for electronic delivery of tax documents will automatically terminate, and I will receive a paper copy of my tax documents by mail at the address that I have provided to SMB VIG.
I may update my contact information by emailing SMB VIG at support@SMBVIG.com.
My tax documents are maintained for 10 years on SMBVIG.com in case I ever need to access them again.
- If I do not consent to receive the tax document electronically, a paper copy will be provided.
- My consent continues for every tax year until I withdraw my consent.
- I may log into My Account at SMBVIG.com to access and print my tax documents. I may need Adobe Acrobat Reader to open the document and a device connected to my computer that can print. In the event a tax document is too large to open in the browser, I will be prompted by a dialog box to save the file to a location on my computer and open it using Acrobat Reader.
- To withdraw consent, I may email SMB VIG at support@SMBVIG.com to request to withdraw my consent.
- If My Account is closed, my request for electronic delivery of tax documents will automatically terminate, and I will receive a paper copy of my tax documents by mail at the address that I have provided to SMB VIG.
- I may update my contact information by emailing SMB VIG at support@SMBVIG.com.
- My tax documents are maintained for 10 years on SMBVIG.com in case I ever need to access them again.
  Where you visit our Site, invest or seek information on investments, then for European law purposes, the SMB VIG entity responsible for the type of Services or offering you engage with or invest with and who will be identified to you in the context of that Service, offering or investment engagement will be a controller.
  If you have any questions, comments or concerns about our Privacy Policy, please email us at privacy@SMBVIG.com
  ELECTRONIC CONSENT AND ELECTRONIC DELIVERY OF DOCUMENTS
  I agree that any time I click or have clicked on an “I Agree,” “I Consent” or other similarly worded button or entry field with my mouse, keystroke or other device, my agreement or consent is legally binding and enforceable against me and is the legal equivalent of my handwritten signature on an agreement that is printed on paper. I agree to be bound by any affirmation, assent or agreement that I transmit, or have transmitted, to or through this website (the “Platform”) by computer or other electronic device, including internet, telephonic and wireless devices, including but not limited to any consent I give or have given to receive communications from SMB VIG LLC. or any of its affiliates, including SMB VIG Advisors LLC and/or SMB VIG Portal LLC, as applicable (“SMB VIG”) solely through electronic transmission.
  I understand that, to the fullest extent permitted by law, any notices, disclosures, forms, privacy statements, reports or other communications, including any tax-related information or documents to the extent provided below (collectively, “Communications”), regarding the investments available on the Platform, and my investment in any such investments, may be delivered by electronic means, such as by e-mail or through SMBVIG.com. I consent to electronic delivery as described in the preceding sentence. In so consenting, I acknowledge that e-mail messages are not secure and may contain computer viruses or other defects, may not be accurately replicated on other systems or may be intercepted, deleted or interfered with, with or without the knowledge of the sender or the intended recipient. I also acknowledge that an e-mail from SMB VIG may be accessed by recipients other than me and may be interfered with, may contain computer viruses or other defects and may not be successfully replicated on other systems. I understand that SMB VIG gives no warranties in relation to these matters.
  I consent to the delivery of tax documents (such as Internal Revenue Service (“IRS”) Form 1099-INT) through SMBVIG.com. I understand that I may withdraw this consent before my tax document is furnished. In providing this consent, I also acknowledge that I have received SMB VIG’s Information on the Electronic Delivery of Tax Documents, included below.
  I further understand and agree to each of the following:
  - As long as my consent remains in effect, SMB VIG may provide all Communications to me electronically in lieu of providing paper Communications.
  - Hardware and software that I will need. Electronic Communications may be provided to me via e-mail and/or the Platform. In order to view and retain the Communications, my computer hardware and software must, at a minimum, be capable of accessing the Internet, with connectivity to an Internet Service Provider or any other capable communications medium, and with software capable of viewing and printing a *.pdf file created by Adobe Acrobat. Further, I must have a personal e-mail address capable of sending and receiving e- mail messages to and from SMB VIG. To print the documents, I will need access to a printer compatible with my hardware and the required software.
  - If these software or hardware requirements change in the future, SMB VIG will notify me through the Platform.
  - To facilitate these services, I must provide SMB VIG with my current e-mail address and update that information as necessary. Unless otherwise required by law, I will be deemed to have received any electronic Communications that are sent to the most current e-mail address that I have provided to SMB VIG.
  - SMB VIG will not assume liability for non-receipt of notification of the availability of electronic Communications in the event my e-mail address on file is invalid, my e-mail or Internet service provider filters the notification as “spam” or “junk mail,” there is a malfunction in my computer, browser, Internet service and/or software, or for any other reasons beyond the control of SMB VIG.
  - I may withdraw my consent to receive Communications in electronic form by emailing SMB VIG at support@SMBVIG.com. If I withdraw my consent to receive Communications in electronic form, SMB VIG may, at its option and in its sole discretion, (A) terminate my account with SMB VIG that was created through the Platform (“My Account”), (B) restrict or limit the actions I may take through or with respect to My Account, including, but not limited to, restricting my ability to purchase SMB VIG investment through My Account, and (C) charge me a fee of $5 for each paper copy of each Communication that would have been provided to me electronically if I had not withdrawn my consent. Any withdrawal of my consent to receive electronic Communications will not affect or impact in any way the terms of this Agreement or my agreement to the Terms of Use Agreement for the Platform.
  Information on Electronic Delivery of Tax Documents
  These provisions relate to my consent above to SMB VIG’s provision of tax documents to me electronically. Prior to furnishing the tax documents electronically, the IRS requires that SMB VIG provide each investor with the following information:

If I do not consent to receive the tax document electronically, a paper copy will be provided.
My consent continues for every tax year until I withdraw my consent.
I may log into My Account at SMBVIG.com to access and print my tax documents. I may need Adobe Acrobat Reader to open the document and a device connected to my computer that can print. In the event a tax document is too large to open in the browser, I will be prompted by a dialog box to save the file to a location on my computer and open it using Acrobat Reader.
To withdraw consent, I may email SMB VIG at support@SMBVIG.com to request to withdraw my consent.
If My Account is closed, my request for electronic delivery of tax documents will automatically terminate, and I will receive a paper copy of my tax documents by mail at the address that I have provided to SMB VIG.
I may update my contact information by emailing SMB VIG at support@SMBVIG.com.
My tax documents are maintained for 10 years on SMBVIG.com in case I ever need to access them again.