Updated October 5, 2017

Christina Development Corporation (“Christina”) respects the sensitive nature of any personal information you provide to us.  We have created this Privacy Policy in order to demonstrate our commitment to the privacy of those who visit our website (the “Site”).  This Privacy Policy describes our online information collection, storage and disclosure practices and the choices you have regarding how your personal information is collected and used by us.  By accessing and using the Site, you consent to the collection, use and disclosure of information through the Site as described in this Privacy Policy.

We reserve the right to change this Policy at any time.  In the event we make changes to this Policy, such policy will be re-posted in the “Privacy” section of our Site with the date such modifications were made indicated on the top of the page.  All changes are effective when posted on this page and will apply to all information that we have about you.  Your continued use after any change is posted indicates your acceptance of the changes.  Because this Privacy Policy contains legal obligations we encourage you to review this Privacy Policy carefully.  If you have any questions concerning this Privacy Policy or our information collection, storage and disclosure practices, please contact us at ir@christinadevelopment.com.

Information We Collect

Christina collects personal and financial information from you when you visit the Site.  The majority of information is collected during the registration and/or application process and, while some items are optional, most are required for legal or security purposes.  You may choose to provide additional information during subsequent visits to the Site, but keep in mind that some of this information will be required if you wish to partake in the services that we provide (“Services”).

In general, the type of information we collect includes, but is not limited to:

  • Personal data required to verify your identity;
  • Personal and financial data necessary to assess your eligibility to utilize the Services on the Christina platform; and
  • un-identifiable and aggregated personal data pertaining to your Site visits that help us maintain the appropriate features, functionality and user experience

Personal Data

Investor registration will require you to provide basic personal data.  Such information typically includes your name, email address, home address and phone number, date of birth, social security number and/or tax identification number, employer and job title.  Christina uses this data to:  (i) enable you to log in to the Site; (ii) establish your ability to view offering materials and to make investments through the Site (for U.S. residents, such ability is restricted to “accredited investors” with a certain level of annual income or net worth); (iii) verify that you are at least 18 years of age; (iv) guard against potential fraud; (v) contact you if there is a problem with your account; and (vi) maintain regular communications with you as may be necessary to inform you of upcoming investment opportunities and other company updates.

Christina will also gather the names and email addresses of users who contact us through the Site with questions about our company. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested to do so.

Financial Data 

When you subscribe to make an investment in one of the offerings on the Site, you will again be asked for your personal data.  You will also be required to provide financial data, such as your bank routing number and bank account number, to enable us or issuers to utilize your bank account to originate funds transfers and make subsequent investment disbursements to you.

Non-Identifiable Data and Aggregated Personal Data

Regardless of whether you register for an account or submit an application, Christina may send one or more “cookies” to your computer.  Cookies are small text files placed on your web browser when you visit our Site that store information on your computer, such as your Site preferences.  We use cookies when you sign in to keep track of your personal session, including some account identifiers to ensure that you are the only person making changes to your account.  We also use cookies to track your activity on the Site as a unique person.  For security purposes, all of this information is stored in encrypted form.

You can set your web browser to inform you when cookies are set, or to prevent cookies from being set altogether.  Please note, however, that if you decline to use cookies, you may experience reduced functionality and slower site response times.  In some instances, declining to use our authentication-related cookies may prevent you from using the Site entirely.

Christina or our service providers may also collect web surfing data related to your use of the Site.  Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Site.  This data may be collected using cookies, web beacons, page tags or similar tools.  As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals.

Web surfing data and similar information may be aggregated for administrative purposes.  Christina may, for example, use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies, and other marketing activities.  We also use it to help optimize the Site based on the needs of our users.

How and When Your Information Is Shared With Other Parties

Christina does not sell, trade or license personal information about its users for marketing purposes.  We do, however, work with a number of trusted partners who perform vital functions as part of our operations.

Additional Sharing of Investor Information

We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business.  Examples of third parties might include those that perform data processing, reporting, tax documentation, electronic payment, electronic signature, 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 perform other specific services, like collections.  Our partners are legally required to keep your information private and secure.

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 the Site or our services, or to protect the rights, property or personal safety of Christina, its users, issuers, or others.

Notifications and Communications from Our Site

Christina will send you email notifications from time to time.  Some notifications are required elements of your transactions on our platform, such as confirmations of particular actions you have taken.  These mandatory notices are sent typically to notify you of a change in status.  For example, you will receive a notice when you are confirmed as an investor.

We also send out notices that are required 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 account without your knowledge.  In other cases, these notifications involve changes to various legal agreements or Site policies.  Generally, you may not opt out of such service-related emails.

When you register as an investor, you will 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 will receive emails when a new investment opportunity is offered, as well as updates concerning the progress of the funding of such offering and/or other relevant information.  If you make an investment through the Site, Christina will also send you confirmations of the investment as well as occasional updates as to the status of that investment and the timing of distributions relating to that investment.

We may also send you responses to emails you send us, if appropriate.  From time to time, we will also send user surveys, requests for user feedback regarding user experience and Site operations, or marketing offers from us or from us on behalf of our marketing partners.  Completing these surveys, answering requests for feedback, or accepting any offer is strictly voluntary. If you do not wish to receive these surveys, user feedback emails, and/or marketing offers, please opt out in any offer email you receive from us.

Where You Can View and Correct Your Information

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 ir@christinadevelopment.com.

Links to Other Sites

If you follow any links that direct you away from the Site, 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.

International Users

Although this Site is intended solely for users within the United States, it may be accessed by users located outside the United States.  If you choose to use the Service 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 Site then you consent to that transfer.

Security Policy

We limit access to the personal information we have about you to those employees who have a legitimate business need to access such information.  We take commercially reasonable steps to protect against unauthorized disclosure or loss of your personal information.  However, no data transmission over the Internet can be guaranteed to be 100% secure.  Therefore, while we strive to protect user information we cannot ensure or warrant the security of any information you transmit to us or from the Site.  You engage in such transmissions at your risk.

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

Children’s Privacy

This Site is restricted to the use of adults over the age of 18.  No portion of the Site is directed to children under the age of 13.  Consequently, we do not collect personal identifying information from any person we know is a child under the age of 13.

Do Not Track

Although some browsers currently offer a “do not track (‘DNT’) option,” no common industry standard for DNT exists.  We therefore do not currently commit to responding to browsers’ DNT signals.

Your California Privacy Rights

Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California customer, a business may be required to provide information regarding how that business has shared personal information of customers with third parties for direct marketing purposes.  However, the foregoing does not apply to businesses like ours that do not disclose personal information to third parties for direct marketing purposes.