1. Introduction
Welcome to Jupiter Smith ("we," "our," or "us"). We are committed to protecting your privacy and
ensuring the security of the information you entrust to us. This Privacy Policy explains how we
collect, use, disclose, and safeguard your information when you access our SaaS platform,
including our deal room, document analysis tools, AI-driven features, and mobile authentication
services (collectively, the "Service").
By accessing or using our Service, you agree to the terms of this Privacy Policy.
2.Information We Collect
We collect information to facilitate connections between microcap issuers, broker-dealers, and
investors, and to provide our AI-driven analytics.
A. Information You Provide to Us
● Account Registration: When you register as an Issuer, Investor, or Investment Banker,
we collect personal details such as your name, professional email address, job title,
company name, and phone number.
● Authentication & Mobile Data: To secure your account, we collect your phone number
directly from you to send One-Time Passcodes (OTP) and security alerts via SMS. This
is part of our Multi-Factor Authentication (MFA) process.
● Deal & Financial Data: We collect sensitive business information you upload to the
platform, including financial statements, pitch decks, and corporate governance
documents used for our "Document Analyzer" and "Deal Rating" features.
● Communications: If you use our secure chat or messaging features to communicate
with other users or our support team, we retain records of those communications.
B. Information Collected Automatically
● Usage Data: We track how you interact with our Service, including which AI modules
(e.g., Issuer Educator) you use, the duration of your sessions, and your navigation paths.
● Device & Log Data: We automatically collect technical data such as your IP address,
browser type, operating system, and access times for security monitoring and SOC 2
audit logs.
3. How We Use Your Information
We use the collected data for the following business purposes:
● Service Delivery: To create and manage your account, facilitate deal room interactions,
and generate AI-driven insights (e.g., Deal Ratings).
● Mobile Security (MFA): Your phone number is used solely to provide the services you
have requested, specifically for account security and authentication purposes via SMS.
We do not use your phone number for marketing campaigns or promotional
messaging.
We may send SMS messages for account verification and security purposes. Message and data rates may apply. You can opt out at any time by replying STOP.
● AI Improvement: To refine the accuracy of our AI models, such as the Issuer Educator
and Document Analyzer. (Note: We do not use your confidential proprietary data to train
models for other clients without your explicit consent.)
● Security & Compliance: To monitor for unauthorized access, enforce MFA, encrypt
database entries, and maintain evidence for our SOC 2 Type 1 compliance.
● Communication: To send you administrative updates, security alerts, and
subscription-related notices.
4. Disclosure of Your Information
We do not sell, lease, or rent your personal information to third parties. We disclose information
only in the following circumstances:
● Strict Prohibition on Sharing Mobile Information: No mobile information will be
shared with third parties/affiliates for marketing/promotional purposes. All the below
categories exclude text messaging originator opt-in data and consent; this information
will not be shared with any third parties.
● Platform Functionality: Your profile and authorized deal data may be visible to other
users (e.g., an Issuer’s data visible to an accredited Investor) strictly based on the
permissions you set within the Deal Room.
● Service Providers: We share non-mobile data with trusted third-party vendors who
assist us in operating our Service, such as:
○ Cloud hosting providers (e.g., AWS).
○ Chat and communication infrastructure providers (excluding mobile opt-in data
for marketing).
○ Security and compliance auditors (e.g., for SOC 2 certification).
● Legal Requirements: We may disclose information if required to do so by law or in
response to valid requests by public authorities (e.g., a court or government agency).
5. Data Security
We implement industry-standard security measures designed to protect your data, including:
● Encryption: Data is encrypted at rest and in transit.
● Access Control: Strict role-based access control (RBAC) and Multi-Factor
Authentication (MFA) for all user accounts.
● Monitoring: Continuous security monitoring and regular vulnerability assessments in
preparation for SOC 2 compliance.
However, no method of transmission over the Internet or electronic storage is 100% secure, and
we cannot guarantee absolute security.
6. Data Retention
We retain your personal and business information only for as long as is necessary for the
purposes set out in this Privacy Policy, or to comply with our legal obligations (such as
record-keeping for financial audits), resolve disputes, and enforce our legal agreements.
7. Your Data Rights
Depending on your jurisdiction, you may have the right to:
● Access the personal data we hold about you.
● Request correction of inaccurate data.
● Request deletion of your account and associated data.
● Export your data in a structured format.
To exercise these rights, please contact us at info@jupitersmith.com.
8. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for
other operational, legal, or regulatory reasons. We will notify you of any material changes by
posting the new Privacy Policy on this page and updating the "Last Updated" date.
9. Contact Us
If you have questions or comments about this policy, please contact us at: Jupiter Smith:
info@jupitersmith.co