Privacy Policy

Last updated: August 21, 2023

This Privacy Policy (“Privacy Policy”) governs the ways that we, Next Street Financial LLC, and our affiliates (collectively, “We”, “Us”, and “Our”) can collect, store, use, process, transfer, share, and delete (“Process”) Personal Information of those who interact with https://nextstreet.com/ (Our “Website” or “Platform”), its subdomains, affiliate websites, or products and services on the Website, or who engage with Us by telephone, email, fax, or other means (“You”, “Your”, and “User”. This Privacy Policy also explains how we Process your Personal Information, Your privacy rights, and how the law protects You.

We use Your Personal Information to provide, maintain, and improve the Platform. By accessing the Website or using the Platform, You agree to Us Processing Your Personal Information in accordance with this Privacy Policy.

Interpretation

Words appearing with capitalized first letters have meanings as defined below. The following definitions have the same meaning regardless of whether they appear in singular or in plural, and the words “include” and “including” will not be interpreted as limitations.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access Our Platform or parts of our Platform.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Next Street Financial LLC a New York for-profit corporation with its principal place of business at 75 Broad Street, Suite 702, New York, New York 10004.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to the United States of America.

Device means any device that can access the Website such as a computer, a cellphone or a digital tablet.

Device Information means information or data disclosed by a User’s Device, such as Internet Protocol (IP) or Media Access Control (MAC) address, or other host-specific persistent static identifiers that consistently link to a particular person or small, well-defined group of people.

Personal Information is any information that, directly or indirectly, and on its own or when combined with any other information, identifies, can be used to identify, relates to, describes, references, or could reasonably be linked to, an individual consumer or device. Personal Information does NOT include information that is publicly available from government records, or de-identified or aggregated consumer information.

Platform means the resource marketplace offered by Company, including the Website.

Service Provider means any natural or legal person who Processes the data on behalf of the Company. It refers to third-party companies or individuals employed or otherwise engaged by the Company to facilitate the Platform, to promote the Platform on behalf of Company, to provide the Platform on behalf of the Company, to perform services related to the Platform, or to assist the Company in analyzing how the Platform is used.

Usage Data refers to data collected automatically, either generated by the use of the Platform or from the Platform infrastructure itself (for example, the duration of a page visit).

Website refers to Next Street, accessible from https://nextstreet.com/.

You means the individual accessing or using the Platform, or the company, or other legal entity on behalf of which such individual is accessing or using the Platform, as applicable.

How We Collect Your Personal Information

We collect Your Personal Information:

  1. Directly from You, when you:
    1. Enter or Provide Us with information. This usually occurs when You provide information by phone, email, or Website upload when applying for, creating, or completing Your Account profile, or submit documents and information to verify Your identity or address.
    2. Contact Us. This usually occurs when You contact by email, phone, or the Website. We ask You to disclose only as much information as is necessary for You to submit Your question/suggestion/comment, and for Us to respond to Your question/suggestion/comment.
  1. Directly and Indirectly from You when You interact with Our Website. This usually occurs when You visit Our Website. The type of Personal Information collected includes Your Device Information.
  2. From third parties that provide maintenance services and enhance the functionality of the Platform, and the products and services advertised on it. This usually occurs when vendors, service providers, and other contractors work with us to analyze Your use of the Platform and the products and services advertised on it.

Types of Data We Collect

We collect the following types of Personal Information about You:

  1. “Sensitive Personal Information” including Your full name, mailing address, financial information, precise geolocation, race and ethnic characteristics;
  2. “Identifiers” including Your full name, alias, unique identifier, login credentials, Device information, email address, SSN, and government identification number;
  3. “Non-Sensitive Personal Information” including Your full name, photograph, description, address, time zone, telephone number, employment, or any other financial information;
  4. “Protected Characteristics” including Your age, date of birth, race, ethnicity, color, citizenship, preferred language, gender (including gender identity and gender expression), pronouns, sexual orientation, veteran or military status, and minority status;
  5. “Commercial Information” including business name, business launch date, entity type, records of revenue, debts, personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  6. “Usage Data” such as Device information, internet and network activity, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, browser type, browser version, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data,
  7. “Professional and Employment Related Information” such as current or past job history; and
  8. “Inferences” such as profile reflecting a person’s Platform preferences, abilities, and aptitudes.

By accessing Our Website or using the Platform, You consent to Us collecting Your Personal Information for the purposes outlined in this Privacy Policy. We will not collect additional categories of Personal Information without Your advance informed consent.


How We Can Use Your Personal Information

We will use the Personal Information we have collected about You solely for the following purposes:

  1. To provide and maintain the Platform, including to monitor the usage of our Service.
  2. To manage and service Accounts: including to manage Your registration as a user of the Platform, provide customer service, verify customer information, provide tailored advertising or marketing services, fulfill the reason for which the Personal Information was provided, provide you with information, products, or services that You have requested from us or which may be of interest to You, provide email alerts and other notices concerning the Platform and the products and services on it that may be of interest to You, and carry out our obligations or enforce our rights arising from any contracts in existence between You and Us. The Personal Information You provide can give You access to different functionalities of the Platform that are available to You as a registered user.
  3. To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, updates, contracted services, or related products, including third party products and services, when necessary or reasonable for their implementation.
  4. To provide You with news, special offers, and general information about other products, services and events offered through the Website or that are similar to those that You have already purchased or inquired about, and that third parties offer but which are similar or related to the aforementioned products and services, unless You have opted not to receive such information.
  5. To audit and verify the accuracy of information provided by You and other users of the Platform, including to verify Your identity or eligibility for certain products or services available through the Platform.
  6. To manage Your requests: To attend and manage Your requests to Us.
  7. For security: To secure the Website and protect Personal Information available on or through it, and to identify and adequately respond to security threats.
  8. For short-term, transient use to enhance website functionality, provided Your Personal Information (such as Usage Data) is not disclosed to a third party or used to build a profile about You or otherwise alter an individual consumer’s experience outside the current interaction, including the contextual customization of ads shown as part of the same interaction.
  9. For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Us about our Service users is among the assets transferred.
  10. For other purposes: We may use Your information for other purposes, such as responding to law enforcement requests and as required by applicable law, court order, or governmental regulations, data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Platform, products, services, marketing, and Your experience. We may also use Your Personal Information for the purpose(s) described to You at the time Your Personal Information is collected or as otherwise set forth in the California Consumer Privacy Act (CCPA).

By accessing Our Website or using the Platform, You consent to Us using Your Personal Information for the purposes outlined in this Privacy Policy. We will not use Personal Information We have collected about You for any purpose that is materially different from, or unrelated to, the purposes described above or the purposes for which the information was collected.

How Long We Will Retain Your Personal Information

Subject to contractual requirements (to the extent they govern our role as a service provider) or legal requirements to the contrary, We will retain Your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. If you terminate Your relationship with Us, You may request in writing that We delete Your Personal Information. We will retain and use Your Personal Information to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your Personal Information to comply with applicable laws), resolve disputes, perform our obligations to You and other users, and enforce our legal agreements and policies.

We will also retain Usage Data and Device Information for internal analysis purposes.

With Whom We Share Your Personal Information

We will share the Personal Information we have collected about You solely for the following purposes:

  1. With Service Providers: We may share Your Personal Information with service providers and contractors to offer and maintain the Platform, to support the availability, management, and provision of the products and services available on the Platform, and to perform Our obligations of any other contract You have with Us. This may include disclosure to service providers to monitor and analyze Your use of the Platform and to contact You. This may also include sharing Your Personal Information with advisors and other professionals on the Platform so that You can communicate directly with them.
  2. For business transfers: We may share or transfer Your Personal Information in connection with, or during negotiations of, any, merger, sale of Our assets, financing, or acquisition of all or a portion of Our business to another company. If the Company is involved in a merger, acquisition or asset sale, Your Personal Information may be transferred. We will provide notice before Your Personal Information is transferred and becomes subject to a different Privacy Policy.
  3. With Affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners, sponsors, or other companies that We control or that are under common control with Us.
  4. With business partners: We may share Your information with Our businesses for whom we are a service provider, including to offer You certain products, services, or promotions available through the Platform, including but not limited to business partners that may provide culturally competent resources or specialized products, services, or promotions to certain minority demographics.
  5. With other users: When You share Personal Information or otherwise interact in the public areas with other users, such information may be viewed by other users and may be publicly distributed outside of our Platform.
  6. With third parties: We may share Your Personal Information with third parties, including those to whom You authorize Us to disclose Your Personal Information in connection with products and services available through the Website, such as:
    1. With Our bank / financing relationships, We disclose Sensitive Personal Information, Identifiers, Non-Sensitive Personal Information, Protected Characteristics, Commercial information, Usage Data, Professional and Employment Related Information, Inferences;
    2. With our advisors such as lawyers, banks, consultants, and insurers We disclose Sensitive Personal Information, Identifiers, Non-Sensitive Personal Information, Protected Characteristics, Commercial information, Usage Data, Professional and Employment Related Information, Inferences;
    3. With governmental and regulatory agencies, We disclose Sensitive Personal Information, Identifiers, Non-Sensitive Personal Information, Protected Characteristics, Commercial information, Usage Data, and Professional and Employment Related Information;
    4. With Our data labeling and organization software providers, We disclose Sensitive Personal Information, Identifiers, Non-Sensitive Personal Information, Protected Characteristics, Professional and Employment Related Information, Commercial Information, Usage Data, and Inferences;
    5. With Our data analytics providers, We disclose Sensitive Personal Information, Identifiers, Non-Sensitive Personal Information, Protected Characteristics, Professional and Employment Related Information, Commercial Information, Inferences, Usage Data;
    6. With Our secure file sharing providers, We disclose Sensitive Personal Information, Identifiers, Non-Sensitive Personal Information, Protected Characteristics, Professional and Employment Related Information, Commercial Information, Inferences;
    7. With Our data security and device management vendors, We disclose Identifiers, Non-Sensitive Personal Information, Usage Data;
    8. With Our communication platforms, We disclose Identifiers, Non-Sensitive Personal Information, Usage Data;
  7. With Your consent: We may disclose Your Personal Information for any other purpose with Your advance informed consent.
  8. To comply with applicable law: We may share Your Personal Information in in the good faith belief that such action is necessary to:
    1. Comply with a legal obligation (including contractual obligations);
    2. Protect and defend Our rights or property;
    3. Prevent or investigate possible wrongdoing in connection with the Platform or the use thereof;
    4. Protect the personal safety of users of the Platform or the public;
    5. Protect against legal liability.

By accessing Our Website or using the Platform, You consent to Us sharing Your Personal Information for the purposes outlined in this Privacy Policy.

How We Transfer Your Personal Information

Your information, including Personal Information, is Processed at the Our operating offices and in other places where the parties involved in the Processing (including Our Service Providers) are located. This means that Your information may be transferred to (and maintained on or by) third parties (such as Service Providers), computers, servers, and/or devices (i) located outside of Your state, province, country or other governmental jurisdiction; (ii) in jurisdictions where the data protection laws may differ than those from Your jurisdiction; and (iii) that are not owned or controlled by Us.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that Processing.

The Company will take all reasonably commercial steps to ensure that Your data is treated securely and in accordance with this Privacy Policy. No transfer of Your Personal Information will take place to an organization or a country unless there are reasonable and adequate controls in place including the security of Your data and other personal information.

Security of Your Personal Information

The security of Your Personal Information is important to Us, but remember that no method of transmission over the internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Information, We cannot guarantee its absolute security.

 

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Website. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of the Platform. Unless You have adjusted Your browser setting so that it will refuse Cookies, the Platform may use Cookies.

Flash Cookies. Certain features of Our Website may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on the Platform. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.

Web Beacons. Certain sections of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You request cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering Your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.

Third Party Cookies. Third party cookies are cookies set by someone other than Us for purposes such as collecting information on Your behavior, demographics, or personalized marketing. When using the Website, You may encounter embedded content or be directed to other websites. The other websites and embedded content may use their own cookies.

Third Party Website Cookie

Type: Third Party Cookies

Administered by: Third Parties

Purpose: Unknown. We do not have control over the placement of cookies by other websites, even if You are directed to them from Our Website.

Children’s Privacy

Our Platform does not address anyone under the age of 13. We do not knowingly collect Personal Information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Information, please contact Us. If We become aware that We have collected Personal Information from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites & Independent Third-Party Activities

The Platform may contain links to other websites that are not operated by Us. We may also provide You with links and offers for third party products and Services related to Your use of the Services. If You click on a third-party link, You will be directed to that third party’s site. Third party sites are not governed by or subject to this Privacy Policy. The third party’s use of Your data is subject to the third party’s privacy policy (if any) and the laws applicable to the third party. We strongly advise You to review the privacy policy of every site You visit.

The Platform also allows You to connect with third-party service providers and other contractors, such as financial advisors and other professionals. Any Personal Information You provide directly to such third parties is not governed by or subject to this Privacy Policy. The third party’s use of Your data (including but not limited to potentially storing Your Personal Information in a customer relationship management system) is subject to the third party’s privacy policy (if any) and the laws applicable to the third party. We strongly recommend that You ask such third parties for a copy of their privacy policy and carefully review that policy before sharing any Personal Information with them.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third parties, including but not limited to their sites or services, even if You are directed to them from Our Website.

Do Not Call Policy

This Section constitutes Our ‘Do Not Call’ Policy under the Telephone Consumer Protection Act for all consumers. We maintain an internal Do Not Call preference list. Do Not Call requests will be honored within thirty (30) days and will be effective for at least five (5) years from the date of request. No telemarketing calls will be made to residential or cellular phone numbers that appear on Our Do Not Call list.Opt-Out of Marketing Communications

You can choose to no longer receive e-mail marketing communications from Us and may express your choice where indicated on the applicable email. Opt-out requests are only effective for, and will only remove You from, Our list and the list of any non-affiliate performing services on Our behalf. We are not responsible for the use any other party may make of Your Personal Information once it has been transferred in accordance with this Privacy Policy and You will need to contact such entity or entities to have Your information removed from their database.

Do Not Track Signals

Our Website does not respond to Do Not Track signals configured in Your web browser.

 

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. We will update the “Last Updated” date with each update to this Privacy Policy.

 

Contact Us

If you have any questions or comments about this Privacy Policy, the ways in which We Process your Personal Information, Your rights regarding such Processing, or wish to exercise Your rights under applicable Data Privacy laws, please do not hesitate to contact Us at:

Email: contact@nextstreet.com

Phone: 646-392-9500

Postal Address: 75 Broad Street, Suite 702, New York, NY 10004

Information for Residents of California

This section provides additional information about the Personal Information We collect and/or Process about California consumers and the rights afforded to them under the California Consumer Privacy Act (“CCPA”). If You are not located in the State of California, U.S.A, the following policies do not apply, and the foregoing sections of the Privacy Policy control.

Definitions

For California purposes, Personal Information does not include any personal information that is covered by sector-specific privacy laws, including the California Financial Information Privacy Act (FIPA), Fair Credit Reporting Act (FCRA), and the Gramm-Leach-Bliley Act (GLBA).

The California Consumer Privacy Act (“CCPA”)

The following subsections to this Privacy Policy apply to Our Processing of Personal Information of California consumers (as the terms “personal information” and “consumer” are defined under the CCPA) (collectively, “Consumers,” “You,” or “Your“). Any capitalized terms or other terms not defined herein have the same meaning ascribed to them in the Privacy Policy or, if not defined herein, the CCPA. To the extent of any conflict between this Privacy Policy and the CCPA, the CCPA shall control only with respect to Consumers and their Personal Information.

Your CCPA Rights

​The CCPA gives California residents specific rights regarding their Personal Information—the Right to Know, the Right to Delete, the Right to Correct, the Right to Opt-Out of the Sale of Personal Information or Sharing of Personal Information, the Right to Limit the Use of Sensitive Personal Information, and the Right to Non-Discrimination. This section describes your CCPA rights.

  1. Right to Know. You have the right to request that We disclose certain information to You about Our collection, use, and disclosure of Your Personal Information over the preceding twelve (12) months (“Request to Know”). Once We receive and verify your Request to Know in accordance with this Privacy Policy, We will disclose to You either:
    1. Categories of Personal Information Processed;
      1. The categories of Personal Information we collected about You;
      2. The categories of sources for the Personal Information We collected about You;
  • Our business or commercial purpose for collecting that Personal Information;
  1. The categories of third parties with whom We share that Personal Information;
  2. If We disclosed Your Personal Information to third parties, the corresponding categories of Personal Information;
  3. If We sold or shared Your personal information for cross-contextual behavioral advertising, the categories of Personal Information sold or shared; or
  1. Specific Information:
    1. The specific pieces of Personal Information We collected about You.
  1. Right to Delete. Subject to certain exceptions, You have the right to request that We delete Personal Information collected and maintained about You (“Request to Delete”). We will delete, de-identify, or aggregate Your Personal Information (and direct our affiliates and service providers to do the same) once Your request has been verified and We have determined that applicable law requires Us to delete that information. Your request to delete Your Personal Information may be denied if it is necessary for Us or our service providers to:
    1. Retain Your information under one or more of the exceptions listed in the CCPA;
    2. Complete the transaction for which the Personal Information was collected, provide a product or service requested by You, or reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform a contract between Us and You;
    3. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
    4. Debug or identify and repair errors that impair existing intended functionality of the Platform;
    5. Comply with a legal obligation.
    6. Otherwise use Your Personal Information, internally, in a lawful manner that is compatible with the context in which You provided the information.

We may also deny your request to delete if we are unable to verify your identity or have reason to believe that the request is fraudulent. A record of Your deletion request may be kept to comply with legal obligations.

  1. Right to Correct. You have the right to request that we correct your inaccurate Personal Information (“Request to Correct”). Once we receive and verify your Request to Correct, we will use commercially reasonable efforts to correct your inaccurate Personal Information in Our records.
  1. Right to Limit the Use of Sensitive Personal Information. You have the right to direct a business that collects Your sensitive personal information to limit its use to uses which are necessary to perform the services or provide the goods reasonably expected. However, we only use Sensitive Personal Information to provide the goods and services requested by You; to prevent, detect, and investigate security incidents; to resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible for such actions; to ensure people’s physical safety; to perform services on Our behalf; to verify or maintain the quality or safety of our Platform and the products and services available through it.
  1. Right to Opt-Out. The CCPA gives consumers the right to opt-out of 1) the sale of their Personal Information and 2) the sharing of their Personal Information for cross-context behavior advertising.

 

Exercising Your CCPA Rights

​Residents of California can exercise their rights under the CCPA by submitting a Request to Know, Request to Delete, or Request to Correct to contact@nextstreet.com.

We will not discriminate against You for exercising any of your CCPA rights. Unless permitted by the CCPA, We will not:

  1. Deny you goods or services;
  2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  3. Provide you a different level or quality of goods or services; or
  4. Suggest that You may receive a different price or rate for goods or services or a different level or quality of goods or services.

Verifying Your Request

​Only You, or a person that You authorize to act on Your behalf, may make a request related to Your Personal Information. In exercising Your CCPA rights related to Your Personal Information, Your request must be verified before We can respond to the exercise.

Verifying Your request will require You to provide sufficient information for Us to: (i) reasonably verify that You are the person about whom We collected Personal Information or a person authorized to act on Your behalf (We may verify Your identity with at least three (3) separate pieces of information We have about You, such as Your Name, Address, Account Number, Date of Birth, Last 4 of your Social Security Number, Phone Number, etc.); (ii) confirm that applicable law requires Us to comply with Your request; and (iii) Describe Your request with sufficient detail to allows Us to properly understand, evaluate, and respond to it.

The Personal Information You provide to verify Your request will only be used to verify the request, and not for any other purpose. We cannot respond to Your request or provide You with Personal Information if We cannot verify Your identity or authority, or the law that applies to You and/or Your Personal Information.

We reserve the right to charge a reasonable fee or refuse to act on a request if the request is excessive, repetitive, or manifestly unfounded.

Your California Privacy Rights under the “Shine the Light” Law

​Section 1798.83 of the California Civil Code (a separate law from the CCPA) provides that residents of California have the right to obtain certain information about the types of Personal Information that companies with whom they have an established business relationship (that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If You would like to submit a request pursuant to this law, please contact Us via email at support@nextstreet.com with the subject line “CA Civil Code”.

Contacting Us

If You have any questions regarding our CCPA privacy practices, please contact Us via email at contact@nextstreet.com with the subject line, “CCPA Policy”.