Effective Jan 1, 2020
Who We Are
MEnvesti Investment Group LLC (together with its partners and affiliates — collectively, “MEnvesti,” “we,” or “us”) provides an online platform to connect the Haitian diaspora to development projects in Haiti. We are a Connecticut for-profit social enterprise with headquarters in Stamford, Connecticut.
Personal Data We Collect (and How We Collect It)
Basic Personal Information. When you create an account on the Website, we collect your name, email address, and a means to authenticate your account (for example, a password). You may also choose to provide additional information, such as your location, a picture, your address, and your payment account identifying information. We may receive some information about you from third-party payment processing providers like PayPal (for example name, payment account email address, and in some cases physical address).
We record information about the Loans you make through the Program, individually (for example, amount and recipient of a Loan) and in the aggregate (for example, number of Loans made and distribution by gender, country, and sector).
Loan Application and Borrowing Activity
If you apply to borrow funds through the Program, we collect information you provide (for example, photograph, email and physical address, phone number, description of business and finances, personal references, desired loan terms, payment account, and certain demographic information), as well as information from third parties (such as your personal references, credit reporting agencies, and public Internet searches). If you are approved to borrow, we record information on individuals you invite to become Lenders, whether or not your Loan is successfully funded, repayments you make, updates you provide to Lenders, and your correspondence with MEnvesti.
Other Use of MEnvesti's Website and Features
We may collect other information you choose to provide in order to facilitate your participation in the Program or use of Website features.
If you make changes to your MEnvesti account preferences (for example, receiving marketing information from us, and whether to donate inactive account funds), we record that information.
We also collect comments you post to any other Web page hosted by MEnvesti (such as a Loan page, blog, or volunteer forum).
Other Interactions with MEnvesti
If you contact MEnvesti customer service, we will collect the information you provide (for example, your name, email address, physical address, phone number and comment) in order to respond to you.
If you submit an application to MEnvesti (for example, to be an employee or volunteer), we collect the information you submit (for example, name, phone number, resume, cover letter, and position of interest) to review your application and follow up with you.
If you participate in a survey or other promotion, we may request certain personal information from you (for example, name, address, and demographic information).
Social Media Accounts
Accessing and Updating Your Personal Information
You have the right to access the personal data MEnvesti has on you. You can view this information through your MEnvesti account. You also have the right to request that we provide some of your personal data to you (or to another third party), in a machine-readable format. To make such a request, or if you have additional questions about information MEnvesti has collected on you, please reach out to us at email@example.com. If your personal information changes, you may update, amend, or remove certain information by signing into your MEnvesti account and making the change in your account settings, or by contacting MEnvesti. We will respond to your requests within 30 days.
How MEnvesti Uses Your Personal Information
to personalize your experience using the Website and to communicate with you about your transactions or other Website activity;
to respond to your comments or inquiries to MEnvesti customer service;
to contact you (including via email) with general information about our initiatives, marketing campaigns, surveys or other promotional activities;
to analyze and improve our services and communications;
to monitor compliance with our policies and standards, and to improve security;
to deliver an invitation to use the Website for you by another User;
to process applications for employment or volunteer positions;
to comply with applicable law or court orders and to exercise or defend our legal rights or the rights of others.
Disclosure of Your Personal Information
MEnvesti does not sell or rent your personal information to third parties. We may share your personal information in the following circumstances:
Publicly, to the extent described in the section below (Information Displayed Publicly).
In order to comply with applicable law, regulation, legal process, or governmental request, or to otherwise protect the rights, property, and safety of MEnvesti, Users, and others.
With our affiliates and service providers, agents and representatives in connection with their provision of services to MEnvesti (for example, account authentication, facilitating Website functionality, processing transactions, distributing MEnvesti emails, conducting surveys, managing employment applications, and monitoring Website traffic and security). All such access shall be under appropriate confidentiality agreements and limited to use to provide services to MEnvesti to help us further our mission.
With third parties providing integrated Website features that you choose to use (for example, Facebook and Twitter) to allow you to share information about your Loans or other Website activity. Please note that we may withhold or withdraw information related to Loans you have made to the extent necessary to protect the privacy of borrowers.
As part of MEnvesti's API, which is a service MEnvesti provides to allow third parties to develop applications and features using information from the Website and Program (“Third Party Applications”). The MEnvesti API may share any information that you display publicly on the Website, and if you authorize a Third Party Application to use your non-public information from the Website (for example, the amount of your available MEnvesti Credit and outstanding Loans) the API may share the non-public information with such Third Party Application. Third Party Application developers have agreed to the MEnvesti API Terms of Service or a separately negotiated agreement, which contain restrictions on the use of your information. Despite these agreements, MEnvesti does not screen or audit Third Party Applications, and we cannot guarantee that third parties will abide by their agreements. You can revoke permissions that you have granted to a Third Party Application through your MEnvesti account settings.
Aggregated or pseudonymized data that does not directly identify you may be shared with third parties for educational, informational or promotional purposes in furtherance of MEnvesti's mission.
Information Displayed Publicly
Lender Profile. When you create a MEnvesti account, the default setting is to have a public profile on the Website. You have the option of changing your profile setting to “anonymous,” which will hide your profile from the public. A public profile displays your first name, area of residence (city, state/province and country), picture, public Lender page URL, and the date on which you created a MEnvesti account. Other information you choose to provide (for example, your occupation, the reasons why you lend, a description of your work, and your website), will be publicly displayed as well.
Once you begin to make Loans, your public profile may automatically display information about the Loans to which you have contributed, and your name and picture may be displayed on the pages for those Loans. MEnvesti may also publicly display your Loan activity, either in a personally identifiable or anonymous manner (depending on your profile setting at the time of such display), for example, as part of a visualization of the current or historical activity on the Website.
If you are approved to raise a Loan as a MEnvesti borrower, some of the information you provided in your application will be displayed publicly on your Loan page on the Website (for example, your first name, business name, picture, location, written narrative, and amount of your Loan request). The status of your Loan request will also be publicly displayed (for example, fundraising, fully funded, expired, or ended). If your Loan is fully funded, your repayment schedule and repayment activity will be viewable by your Lenders and Trustee (if applicable), including information on whether you have missed repayments or are in default.
MEnvesti hosts various publicly accessible blog pages and community forums. Any information you provide in these areas may be viewed by others who access them.
How Long We Keep Your Personal Information
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for. Our standard retention periods are as follows:
Cookies and other Website browsing data (including IP addresses) of Users who do not have a MEnvesti account: deleted no later than two years from date of collection.
Communications with Users who have contacted MEnvesti via email: deleted two years after the User’s last message to MEnvesti.
Applications for employment or volunteer positions with MEnvesti: deleted no later than three years after application date.
Contact information and lending history of offline lenders: kept for as long as may be relevant to facilitate loans.
Personal data of MEnvesti borrowers: kept indefinitely for data integrity and fraud prevention purposes.
MEnvesti reserves the right to retain indefinitely data that does not directly identify you, for example, aggregated or anonymized data.
How to Limit Our Use of Your Personal Information
In certain circumstances, you have the right to restrict MEnvesti's use and storage of your personal information. For instance, you may ask us to erase your personal data when it is no longer necessary for the purposes for which it was collected. If our collection and use of certain personal information is based on your consent, you have the right to withdraw your consent. In such case, we will no longer process your information unless there is another legal ground to do so. You may ask us to limit our use of your personal data or to erase your personal data by contacting us at firstname.lastname@example.org. As certain personal information is necessary for your participation in the Program, we will be unable to delete that information unless you choose to close your MEnvesti account. You may close your account at any time and for any reason by sending a written notice of termination to MEnvesti along with instructions for the disposition of your then-available MEnvesti Credit and any additional credits that your beneficiaries may receive in the future (for example, repayments toward then-outstanding and active Loans), such notice to be effective within three days of receipt by MEnvesti.
Security of Your Personal Information
MEnvesti takes reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse and unauthorized access, disclosure or modification of personal information. While we take these reasonable efforts to safeguard your personal information, no system or transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.
Electronic Communications and Emails
You will receive certain notices and information based on your account status or activity (collectively, "Communications") from MEnvesti (for example, confirmations of Loans you have made, statements with respect to the amount of MEnvesti Credit available in your account, confirmation of email address or password changes, and inquiries regarding activity in your account). By creating a MEnvesti account, you agree that all Communications from MEnvesti relating to your use of the Website and participation in the Program may be made electronically by email or at the Website (although we reserve the right to provide you with certain Communications through physical mail). To access the Communications, you will need to use a computer with Internet Explorer 10.0 or above, Chrome 4.0 or above, Safari 4.0 or above, Opera 10.0 or above or Firefox Internet browsers and with hardware capable of running these browsers. You may withdraw your consent to receive Communications electronically by contacting MEnvesti as described below. However, if you withdraw your consent to receive electronic Communications (other than for the optional emails described below), you will not be able to fund any additional Loans through the Website. The withdrawal of your consent will not affect the legal validity of electronic Communications provided before you withdraw your consent, or in connection with any of your Loans that have not been fully repaid by the time you withdraw consent. It is your responsibility to inform MEnvesti of any changes to your email address so that you continue to receive all Communications without interruption. You may request a paper copy of any electronic notice from MEnvesti by sending an email to , including your name and the address to which you would like the paper copy sent. By default, you will receive the following types of optional emails from MEnvesti: news and promotions, portfolio and balance updates, and Loan and borrower updates. Note that if you have a public Lender profile, other Users will be able to send you messages through the Website. You have the right to object to receiving these optional emails from MEnvesti, and you can stop receiving them by clicking an “unsubscribe” link in an email, or by changing your email preferences in your account settings.
Third Party Applications and Links to Other Websites
Location of Data
Children Under the Age of 13
The Website is intended to be used by adults. It is not intended for children, and MEnvesti does not want to collect any personal information about individuals under the age of 13. MEnvesti recommends that parents do not post, or permit others to post, any personally identifiable information with respect to children under the age of 13. If you believe that we have any information from a child under age 13, please let us know at email@example.com.
If you believe that any of your rights with respect to your personal data have been breached, you may also lodge a complaint with the appropriate supervisory authority or seek a remedy through the courts.