Privacy Policy

Effective date: October 17, 2022

This Privacy Policy (the “Privacy Policy”) describes Draper Walled Garden, Inc.’s (“DWG”, “we”, “us” or “our”) policies and procedures on the collection, use and disclosure of your information when you use the services, websites (collectively, the “Site”), and mobile applications (collectively, the “App”) offered by DWG (such services, the Site and the App collectively, the "Services") and tells you about your privacy rights. By using the Services, you consent to our use of your information in accordance with this Privacy Policy. We will not use or share your personal information with anyone except as described in this Privacy Policy. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms and Conditions.

We will post any modifications or changes to this Privacy Policy on this page.

Who We Are and How to Contact Us

Who we are. Draper Walled Garden, Inc. (DWG) is the controller of your Personal Data (referred to as either "DWG", "we", "us" or "our" in this Privacy Policy). Our address is 55 E 3rd Ave, San Mateo, CA 94401.

How to contact us. If you have any questions about our Privacy Policy, please contact us at

Your Rights Relating To Your Personal Data

Under this Privacy Policy you have the right to:

  • Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue processing it.
  • Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to the processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you in certain scenarios (for example if you want us to establish its accuracy or the reason for processing it).
  • Request the transfer of your Personal Data. Upon your request we will provide to you, or a third party you have designated, with your Personal Data in a format that is structured, commonly used and machine-readable. Note that this right only applies to automated information which you either initially provided consent for us to use or which we used to perform a contract with you.
  • Withdraw consent. This right only exists where we are relying on your consent to process your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain products or Services. We will advise you if withdrawal of your consent will affect our ability to provide you with access to any products or Services at the time you withdraw your consent.

How to exercise your rights. If you wish to exercise any of the rights described above, please contact us using the contact information provided in the “Who We Are and How to Contact Us” section above. If you wish to limit our sharing of your Personal Data, you can notify us via a form, available upon request from

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights described above). However, if in our sole discretion we believe your request is clearly unfounded, repetitive or excessive, we may charge you a reasonable fee or refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to enable us to more promptly respond to the request.

We try to respond to all legitimate requests within one month of receiving each applicable request. Occasionally it may take us longer than a month to respond if your request is particularly complex or if you have made a number of requests. If our response will take longer than a month, we will notify you and keep you updated regarding the status of the response.


If you would like to submit a complaint regarding this Privacy Policy or any of our practices in relation to your Personal Data, please contact us at:

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, you may lodge a complaint with the competent data protection authority regarding the processing of your Personal Data.

Marketing Communications Preferences

You can ask us to stop sending you marketing messages or modify your email preferences at any time by following the opt-out links in any marketing message sent to you.

Personal Data We Collect

DWG uses Personal Data we collect to provide the Services, personalize content, remember information to help you efficiently access your account, analyze how the Services are used, diagnose service or technical problems, maintain security and monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns.

Information You Directly Provide to Us. There are many occasions when you provide information that may enable us to identify you personally ("Personal Data") while using the Services. The Personal Data we may collect from you is outlined and described in the table below.

Category of Personal Data collected What this means
Identity Data First name, last name, username or similar identifier, title, date of birth and gender
Contact Data Your home address, work address, billing address, email address and telephone numbers.
Online Presence Data Links to your public account pages at social media websites, links to personal websites, and other online materials related to you.
Financial Data Your bank account and payment card details, statements about your wealth and financial situation.
Transaction Data Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third parties.
Usage Data Information about how you use the Services.
Marketing and Communications Data Your preferences in receiving marketing from us and our third parties and your communication preferences. If you correspond with us by email or messaging through the Services, we may retain the content of such messages and our responses.
Technical Data Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site/App or otherwise use our Services.

Personal Data from Third Party Sources. In addition to the Personal Data that we collect directly from you (as described in the section immediately above), we may also collect certain of your Personal Data from third party sources, some of which may not be publicly available (e.g. social media sites, our affiliates, advertisers, analytics providers and/or data brokers).

Aggregated Data. We may also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data, but is not considered Personal Data as such data will not directly or indirectly reveal your identity.

How We Use Your Personal Data and Why

We generally use Personal Data for the following: to deliver and improve our Services; to manage your account and provide you with customer support; to perform research and analysis about your use of the Services; to develop, display, and track Content and recommendations tailored to your interests through the Services and other sites, including, potentially, providing our advertisements to you when you visit other sites; Site/App analytics; to diagnose or fix technology problems; to automatically update the Services on your device; to verify your identity and prevent fraud or other unauthorized or illegal activity; and to enforce or exercise any rights in our Terms and Conditions;

We collect and use your Personal Data only where:

  • We need it to provide you with the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
  • Processing of your Personal Data is necessary for the performance of a contract to which you are a party or to protect your vital interests or that of another person;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; or
  • We need to process your data to comply with a legal or regulatory obligation.

We may also rely on your consent as a legal basis for using your Personal Data where we have expressly sought it for a specific purpose. If we do rely on your consent to our use of your Personal Data, you have the right to change your mind at any time (however, this will not affect any processing of your Personal Data that has taken place prior to the withdrawal of your consent). Purposes for which we may use your Personal Data and more descriptive examples of related reasons we may use your Personal Data in connection with such purpose are described in the table below.

Purpose Why we use your Personal Data
Providing, updating, and maintaining our Services, the Site/App and related business activities To deliver the Services you have requested, including, for example, registering you as a user, managing your account and profile, and authenticating you when you log in to the Site/App.
Research and development To enable us to improve the Services and better understand our users and the markets in which we operate. For example, we may conduct or facilitate research and use learnings about how people use our Services as well as feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns, areas for additional features and improvement of the Services and other insights. We also test and analyze certain new features with some users before introducing the feature to all users.
Communicating with users about the Services To send communications via email and within the Services, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative, billing and account management related messages. We may also provide tailored communications based on your activity and interactions with us. For example, we may notify you of investment opportunities we think you may be interested in, and provide information regarding your investments through the Site/App.
Providing customer support To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support.
Enhancing security To keep our Site/App, our Services and associated systems operational and secure, including, for example, verifying accounts and activity, monitoring and investigating suspicious or fraudulent activity and identifying violations of any of our terms and policies.
Marketing, promoting and driving engagement with the Services and third-party products and services To send promotional communications that may be of specific interest to you, including, for example, through email and by displaying products, investment opportunities, events, promotions and other information on the Site/App or other companies' websites. These communications may be aimed at driving engagement and maximizing what you get out of the Services or promoting third-party products and services. You generally can control whether you receive these communications as described in this policy under the “Marketing Communications Preferences” section above.
Complying with applicable law, legal process and regulations and protecting legitimate business interests As we believe is reasonably necessary to comply with a law, regulation, order, subpoena, rule of a self-regulatory organization or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect our legal rights, interests and the interests of others, such as, for example, in connection with the acquisition, merger or sale of securities or a business (e.g. due diligence).

What happens when you do not provide necessary Personal Data?Where we need to process your Personal Data either to comply with a legal or regulatory obligation or to perform the terms of a contract we have with you, and you fail to provide any such Personal Data when requested, we may not be able to perform the contract we have with you or are trying to enter into with you (for example, to provide you with the functionalities of the Services). In this case, we may have to terminate your access to the Services.

How We Use Cookies And Other Tracking Or Profiling Technologies

DWG may collect non-personally identifiable information regarding your usage of the Services, including the pages, articles and presentations you viewed, time spent using certain features of the website, demographic data such as server locations, connection speed, and other information that does not directly identify you. Like most online services, we also use cookies, log files, clear GIFs, tracking pixels, web beacons and other technologies that may collect Personal Data.


What are cookies? When you visit the Services, we may send one or more "cookies" – small data files – to your computer or mobile device to uniquely identify your browser and to enable DraperX to help you log in faster and enhance your navigation through the Site/App. A cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect personal information about you. A persistent cookie remains on your computer after you close your browser so that it can be used by your browser on subsequent visits to the Site/App. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser.

What cookies do we use? Our Site/App use the following types of cookies for the purposes described below:

Type of cookie Purpose
Essential Cookies These cookies are essential to provide you with services available through our Site/App and to enable you to use some of their features. For example, essential cookies allow you to log in to secure areas of our Site/App and help quickly load the content of the pages you request. We cannot provide you with the Services without these cookies, and we only use these cookies to provide you with the Services.
Functionality Cookies These cookies allow our Site/App to remember choices you make when you use our Services, such as remembering your login details and remembering the changes you make to other parts of our Site/App or other Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid requiring you to re-enter your preferences every time you visit our Site/App.
Analytics and Performance Cookies These cookies are used to collect information about traffic to our Site/App, and how users use our Services. The information gathered via these cookies does not "directly" identify any individual visitor. However, it may render such visitors "indirectly identifiable" because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site/App. The information collected is aggregated and anonymous. We use this information to help our Site/App operate more efficiently, to gather broad demographic information and to monitor the level of activity on our Site/App. We use a number of different tools for this purpose.
Targeting and advertising cookies These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show you advertisements which we think will be relevant to your interests while you are on third party websites. Third party advertisers may also use other technologies in addition to cookies placed on the Site/App to measure the effectiveness of their advertisements and to personalize the advertising content.
Social Media Cookies These cookies are used when you share information using a social media sharing button or "like" button on our Site/App or you link your account or engage with our content on or through a social networking website. The social network will record that you have done this. These cookies may also include certain code that has been placed on the Site/App to help track conversions from ads, optimize ads based on collected data, build target audiences for future ads, and remarket to qualified leads, i.e. users who have already taken certain action on our Site/App.

How can I disable cookies? You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. To refuse cookies or request that your browser notify you when a cookie is being sent, you should follow the instructions provided by your browser (usually located within the "settings", "help", "tools" or "edit" facility). Note that many browsers are set to accept cookies until and unless you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services and some features of the Services may not function properly. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site/App.

Do Not Track Signals: We do not currently respond to web browsers' "do not track" signals that provide a method to opt out of the collection of information about users' activities using the Services and on other websites. If we do so in the future, we will update this Privacy Policy to provide any relevant information.

Log Files: Log file information is automatically reported by your web browser each time you access a web page. When you use the Services, our servers automatically record certain information your web browser or mobile apps send whenever you visit any website. These server logs may include information such as your web request, IP address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed and other such information.

Clear GIFs Information (Web Beacons): When you use the Services, we may employ clear GIFs (also known as web beacons or tracking pixels) to anonymously track online usage patterns. No personally identifiable information from your DraperX account is collected using these clear GIFs. In addition, we may also use clear GIFs in HTML-based emails sent to our Users to track which emails are opened by the recipients. The information collected is used to enable more accurate reporting and to improve the Services we provide.

Third Party Services

DraperX may use third party services to help understand use of the Services. These third party services typically collect the information sent by your browser as part of a web page request, including cookies and your IP address. Third party services’ receipt of such information and their use of such information is governed by the services’ respective privacy policies.

Who We Share Your Personal Data With

We may share your Personal Data with third parties for the reasons described in the table below. We consider this information-sharing to be a vital part of managing, maintaining and improving our relationship with you.

Recipients Why we share it
Our Affiliates Our affiliates may access your Personal Data to help us develop, maintain and provide our Services and help manage our customer relationships.
Service Providers Our service providers provide us support for our Services, including, for example, website and mobile application development, hosting, maintenance, backup, storage, virtual infrastructure, analysis, identity verification, background and compliance reviews and other services for us, which may require them to access or use your Personal Data.
Professional Advisers Our lawyers, accountants and auditors may need to review your Personal Data to provide consultancy, compliance, legal, accounting and similar services.
Legal and Taxing Authorities, Regulators and Participants in Judicial Proceedings DWG may disclose your Personal Data if we believe it is reasonably necessary to comply with a law, regulation, order, subpoena, rule of a self-regulatory organization or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect our legal rights, interests and the interests of others, such as, for example, in connection with the acquisition, merger or sale of securities or a business (e.g. due diligence).
Advertisers Certain users of the Services may have access to your Personal Data for the purpose of enabling them to interact with you and more effectively offer opportunities through the Site/App that are targeted towards your background and preferences. We may also allow third parties, including ad servers or ad networks, to serve advertisements on the Site/App. Such third parties may be provided with access to your Personal Data to provide advertising tailored to your interests.
Researchers To enhance the public understanding of patterns and trends in the markets served by our Services, we may provide Personal Data to third parties under confidentiality obligations such as, for example, academics or contractors, for research purposes.
API Users A limited number of partners may have API access to portions of the Site/App. Examples of the most common API use is AML/accreditation verification of potential investors.

As we develop our business, we may buy or sell businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, we may also transfer your Personal Data as part of the transferred assets without your consent or notice to you.

We may also share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services or conduct independent research based on such anonymous usage data.

If you request that we revise or remove your Personal Data as described in the “Your Rights Relating to Your Personal Data” section above, we will convey that request to any third party with whom we have shared your Personal Data. However, we are not responsible for any third party’s revision or removal of any of your Personal Data that is held by such third party, with respect to any third party who we previously provided with your information in accordance with this Privacy Policy or any third party to whom you previously provided such information (whether by sharing your login and password, or otherwise).

How long we store your Personal Data

We will retain your Personal Data for as long as your account is active or it is reasonably needed for the purposes set out in the “How We Use Your Personal Data and Why” section above, unless you request that we remove your Personal Data as described in the “Your Rights Relating to Your Personal Data” section above. We will only retain your Personal Data for as long as we reasonably need to use it for such purposes unless a longer retention period is required by law (for example, for regulatory purposes). This may include keeping your Personal Data after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal or regulatory obligations, resolve disputes and enforce our agreements.

Where We Store Your Personal Data

Personal Data that you provide us may be stored, processed and accessed by us, our staff, sub-contractors and third parties with whom we share Personal Data in locations inside or outside the United States of America for the purposes described in this Privacy Policy. We may also store Personal Data in locations outside the direct control of DWG (for instance, on servers or databases co-located with hosting providers).

How We Protect Your Personal Data

DraperX uses industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We periodically review our policies and procedures regarding access and storage of your Personal Data to evaluate their effectiveness and ensure that they remain up to date. We cannot, however, ensure or warrant the security of any information you transmit to DraperX or guarantee that any information you provide in using the Services may not be accessed, disclosed, altered or destroyed by a breach of any of our physical, managerial or technical safeguards.

We have put in place procedures to respond to any actual or suspected Personal Data breach. In the event that Personal Data is compromised as a result of such a breach of security, DWG may promptly notify those persons whose Personal Data has been compromised via the functionality of the Services or email. You may have a legal right to receive this notice in writing.

DWG cannot ensure that your Personal Data will be protected, controlled or otherwise managed pursuant to this Privacy Policy if you share your login and password information with any third party, including any third party operating a website browser or providing other services.

Third Party Websites, Plug-ins and Applications

The Site/App may include links to third party websites, plug-ins and applications that use or are integrated with our Services. Clicking on those links or enabling those connections, including the integration of third party applications into your use of the Services, may allow third parties to collect or share information about you. We do not control these third party websites and applications and are not responsible for their privacy policies or their handling of your information. Your enablement, access or use of these third party websites and applications are governed solely by the terms and conditions of the third parties’ respective privacy policies. We encourage you to review the privacy policies of all third party applications you decide to use and any websites you visit after leaving the Site/App. In certain cases, you may be required to register for or log into such third party applications on their respective websites. By enabling the use and integration of your selected third party applications, you are expressly permitting DWG to disclose your login as well as your Personal Data to such third party applications as necessary to facilitate your enablement and use of such third party applications in connection with your use of the Services.

Our Policy on Children's Privacy

Protecting the privacy of young children is especially important. The Services are not intended for children or anyone below twenty-one (21) years of age. DWG does not knowingly collect or solicit personal information from anyone under the age of twenty-one (21) years and DWG does not knowingly allow such persons to register with the Services. If you are under the age of twenty-one (21), please do not submit any personal information through the Site/App. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information on the Site/App. If we become aware that we have collected personal information from a child or anyone under the age of twenty-one (21), we will take steps to remove that information.

Changes to Our Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the Effective Date below. Your continued use of the Services following the date on which any changed or updated Privacy Policy is published will constitute consent to such changes or updates.

Accurate and Current Personal Data

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed of any changes to your Personal Data during your relationship with us.

Additional provisions for EU residents

Why and how we process your personal data

Your personal data will not be used for automated decision-making, including profiling.

How to contact the appropriate authority

If you feel that Our Company has not addressed your concern in a satisfactory manner and you wish to lodge a complaint, you may contact the European Data Protection Supervisor (