Privacy Policy

Effective: 8/30/2023

We are committed to protecting your privacy and preserving your trust. Please carefully review this Privacy Policy (the “ Privacy Policy“), which provides transparency about our privacy practices including how Mainshares LLC, a wholly-owned subsidiary of Pine Street Labs, Inc., and its affiliates (together “Mainshares“, “We“, “Us“, “Our“ and the “Company“) collect, process, and disclose any Personal Information, and how you can control and manage your privacy choices.

In this Privacy Policy, a “User“ or “You“ refers to any of the following: (i) visitors of Mainshares and its affiliates’ websites (e.g., mainshares.com) (collectively, the “Mainshares Platform“), (ii) individuals who interact with Mainshares or its Services (as defined below), and (iii) individuals who create an account on the Mainshares Platform, including “Issuers“ and “Investors“ (collectively, “Platform Participants“).

By using the Mainshares Platform, you agree to this Privacy Policy. You acknowledge and consent to our privacy practices as described below. Failure to maintain compliance with this Privacy Policy may result in losing access to the Mainshares Platform and the Services.

Table of Contents

1. Scope and Applicability

2. Information We Collect and Receive

3. Our Uses of Personal Information

4. How We Share Information

5. Communications and Marketing

6. Data Retention and Disposal

7. Cookies and Other Identifiers

8. Third-Party Sites, Blogs, and Social Media

9. General Data Protection Regulation and International Transfers

10. California Residents

11. Your Privacy Preferences

12. Children’s Data

13. Main Street Securities LLC

14. Information Security

15. Breach Notification

16. General Inquiries and Updates

I. Scope and Applicability

The scope of this Privacy Policy applies to Mainshares and any of our affiliates with whom we may share Personal Information and encompasses all of our Services (operated offline, online, or both) including services made available through the Mainshares Platform (which includes websites, applications, and online services) including, but not limited to, our advisory consulting and offering support Services (collectively, the “Services“), and when you otherwise interact with us, such as through our customer service channels.

Our relationship with you will determine how this Privacy Policy applies to you and your information. In general, if you engage with us directly and independently of a third party, this Privacy Policy applies. To the extent that your information is processed by an independent third party (e.g., identity verification provider), then that third party may be responsible for your privacy with respect to that information. If you have any questions as to who is responsible for your information, you may contact support@mainshares.com.

II. Information We Collect and Receive

a. Registered Users. Registered Users are persons who sign up and create a user account with us via the Mainshares Platform (“Registered Users“). We may collect the following Personal Information from Registered Users:

• Your name;
• Your email address;
• Your username;
• Your password(s);
• Your Google information if you are signing up via Google (this will authenticate your identity and link your information, such as your name, profile image, and email address, to your account);
• Your biographical information as used in your profile;
• Your address or geographic location; and
• Your profile image.

b. Entrepreneurs. Entrepreneurs are Registered Users (whether natural persons or entities) who have decided to participate in the Service offerings, including but not limited to Copilot (as defined in the Terms of Service). We may collect the following Personal Information from Entrepreneurs:

• Legal physical address;
• Telephone number;
• Date of birth;
• Tax ID number or social security number, as applicable, citizenship status, and state or country of formation for investment entities, if applicable;
• Responses to further questions answered during the profile creation;
• Further information to help validate your identity such as your driver’s license information or government-issued identification number; and
• We may collect additional information (e.g., financial and reputational due diligence) as needed.

c. Investors. Investors are Registered Users (whether natural persons or entities) who have applied to participate in investment opportunities found on the Mainshares Platform via the Mainshares investment portal (the “Investment Portal“). We may collect the following additional Personal Information from Investors:

• Legal physical address;
• Telephone number;
• Date of birth;
• Business name, address, email, phone number, and names of owners and management, if applicable;
• Balance sheets, profit and loss statements, bank account information, average bank balance, bank statement, entity formation documents, and other financial data, including tax returns, as applicable, to help verify your accreditation status or “Qualified Purchaser” status;
• Tax ID number or social security number, as applicable, citizenship status, and state or country of formation for investment entities, if applicable;
• Responses to further questions answered during the profile creation; and
• Further information to help validate your identity such as your driver’s license information or government-issued identification number.

d. Issuers. Issuers are Registered Users who have applied to raise capital via a registration exemption using the Mainshares Platform and Investment Portal. We may collect additional information (e.g., financial and reputational due diligence) as well as that which we would collect from an Investor.

III. Our Uses of Personal Information

Mainshares will use Personal Information to:

• Operate and provide you with the Services;
• Communicate with you and send you marketing communications;
• Keep your account secure and protect the Mainshares Platform, Investment Portal, Services provided, and other Platform Participants;
• Analyze your preferences, interests, and behavior to provide you with tailored content and the most relevant content and communications;
• Enforce our Terms of Service, enforce our legal rights, comply with applicable law, and respond to government and legal requests; and
• To determine demographics of platform usage.

Main Street will use Investor and Issuer Personal Information to:

• Assist the parties in structuring the capital raise required to finance the purchase of a small business;
• Verify your identity and status with respect to securities and other laws;
• Record your investment with a third-party SEC-registered transfer agent;
• For other purposes for which we provide specific notice at the time of collection of the information.

Lawful Basis for Processing. Depending on your circumstances and your relationship with Mainshares and Main Street, either party may process your Personal Information on the following lawful bases:

• Consent: where you have given consent to the processing of his or her Personal Information for one or more specific purposes;
• Contract: where the processing is necessary for the performance of a contract with you (e.g., to deliver the service you have requested);
• Legal Obligation: where processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., for compliance with securities laws); and
• Legitimate Interests: where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, not overridden by the interests or fundamental rights and freedoms of the data subject, (e.g., for product development and analytics purposes).

IV. How Personal Information is Shared

Mainshares shares and discloses Personal Information to other parties as needed to provide our Services and operate our business. The categories of other parties with whom we may share information include:

• The Mainshares Affiliates and Subsidiaries. Mainshares may share Personal Information about you with affiliates and subsidiaries.
• Service Providers. We may share the information that you have provided us with certain third-party services, including payment processors, web services providers, developers, security and storage service providers, analytics service providers, and providers used to analyze our websites’ and applications’ functionalities.
• Business Services. We may share any category of Personal Information with our business services providers in the operation of our business and facilitation of the Services, including agents, auditors, financial institutions, and professional advisors.
• Corporate Activities. We may share any category of Personal Information with other companies or entities as part of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock. In such case, your Personal Information may be transferred to the potential or actual acquirer, successor, or assign.
• Government and Legal. We may share any category of Personal Information with other parties, including public authorities, as required by applicable law, regulation, or legal process.

Main Street shares and discloses Personal Information to other parties as needed to provide the Capital Services (as defined in the Terms of Service). The categories of other parties with whom Main Street may share information include:

• The Main Street Affiliates and Subsidiaries. Main Street may share Personal Information about you with affiliates and subsidiaries.
• Service Providers. Main Street may share the information that you have provided Main Street with certain third-party services, including payment processors, web services providers, developers, security and storage service providers, analytics service providers, and providers used to analyze our websites’ and applications’ functionalities.
• Business Services. Main Street may share any category of Personal Information with Main Street’s business services providers in the operation of their business and facilitation of the Captial Services, including agents, auditors, financial institutions, and professional advisors.
• Corporate Activities. Main Street may share any category of Personal Information with other companies or entities as part of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock. In such case, your Personal Information may be transferred to the potential or actual acquirer, successor, or assign.
• Government and Legal. Main Street may share any category of Personal Information with other parties, including public authorities, as required by applicable law, regulation, or legal process.

V. Communications and Marketing

When you sign up for our Services, we will send periodic emails to you regarding the Services or tell you about new Services we believe will interest you; generally, such notices will specify which member of Mainshares has sent it to you. You may also subscribe to our blog and newsletter or sign up to hear about investing opportunities.

You can also opt out of promotional or marketing email communications, including affiliate marketing, by clicking on the unsubscribe link in any email you receive from us, by accessing your notification settings by logging into your account, or by contacting us at support@mainshares.com.

Please note: Opting out will not unsubscribe you from important communications regarding your Mainshares Platform account, security-related matters, or those notices required by applicable law.

VI. Data Retention and Disposal

Mainshares and Main Street retain Personal Information in accordance with applicable law. Certain Personal Information subject to record retention requirements (e.g., under SEC and FINRA rules and regulations) may be retained for at least 7 years for legal and compliance purposes, as well as with respect to relevant statutes of limitations.

VII. Cookies and Other Identifiers

We use cookies throughout our websites and web applications to track user interactions, personalize your experience as a Platform Participant, and promote our Services. Cookies are small files stored on a computer designed to hold small amounts of data specific to a user and the websites or applications to help tailor that user’s experience.

VIII. Third-Party Sites, Blogs, and Social Media

Our website includes links to other websites whose privacy practices may differ from ours. When you use a link to go from our website to an unaffiliated website, the privacy policy of the other website will apply.

Our website offers a publicly accessible blog. Information you provide in relation to blogs, including comments, may be displayed publicly and read, collected, and used by others who access them. To request the removal of your Personal Information from our blog, contact us at support@mainshares.com. In some cases (e.g., comments made on a deal page within the Investment Portal must be retained by law), we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

Our website includes social media features, such as a Facebook Pixel, that run on our website. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features may also be governed by the privacy policy of the company providing such feature.

IX. General Data Protection Regulation

Mainshares is based in the United States and your Personal Information may be collected and processed in the United States. Mainshares has affiliates outside of the United States. If transferred, data is transferred subject to appropriate transfer mechanisms and safeguards.

• If you are outside the United States, you use or access the Mainshares Platform and Investment Portal solely at your own risk and initiative. The Mainshares Platform and Investment Portal are controlled and operated from facilities within the United States.
• Mainshares and Main Street make no representations that the Mainshares Platform nor the Investment Portal are appropriate or available for use in any other jurisdictions.
• Accessing the Mainshares Platform and Investment Portal is prohibited from territories where the content on the Mainshares Platform or Investment Portal is prohibited.

WE MAKE NO REPRESENTATION THAT THE CONTENT ON THE MAINSHARES PLATFORM CONFORMS TO YOUR LOCAL LAWS, AND IF YOU ARE ACCESSING THE MAINSHARES PLATFORM FROM A LOCATION OUTSIDE THE UNITED STATES, YOU ALONE ARE RESPONSIBLE FOR COMPLIANCE WITH YOUR LOCAL LAWS.

X. California Residents

Privacy Rights of California Residents. If you are a California resident, under the California Consumer Privacy Act (“CCPA“) and its successor, the California Privacy Rights Act (“CPRA“) you have additional rights regarding your Personal Information. Subject to certain limitations, your rights include:

• Right to Know. You have the right to know and see what Personal Information Mainshares has collected about you over the preceding 12 months, including:
  • the categories of Personal Information Mainshares has collected about you;
  • the categories of sources from which Personal Information is collected;
  • the purposes for collecting your Personal Information in accordance with the Services;
  • the commercial purposes for collecting your Personal Information;
  • the categories of third parties with whom Mainshares has shared your Personal Information; and
  • the specific pieces of Personal Information Mainshares has collected about you.
• Right to Deletion. You have the right to request that Mainshares delete the Personal Information we have collected from you. However, there are exceptions under which we may retain your Personal Information and where we are not required to delete your Personal Information.
• Right to Correction. You have the right to request that Mainshares correct the Personal Information collected from you.
• Right to Portability. You may have the right to request that we transfer certain Personal Information to another entity, subject to certain exceptions.
• Right to Opt-Out of the Sale or Sharing of Personal Information. We do not “sell” or “share” Personal Information as defined by the CCPA or the CPRA. You have the right to opt out of any processing for cross-context behavioral advertising, targeted advertising or profiling in connection with decisions that produce legal or similarly significant effects, if applicable.
• Right to Opt-Out of Automated Decision-Making. You have the right to opt out of automated decision-making, if applicable.
• Right to Opt-Out of the Use and Disclosure of Sensitive Personal Information. If we collect sensitive Personal Information, we will restrict its use to what is necessary to perform the Services requested by you.
• Right to be free from discrimination. You can be free from discrimination for exercising your rights under the CCPA/CPRA.

If you are a California resident and would like to exercise your rights in accordance with the CCPA, you may contact Mainshares via email at support@mainshares.com. We will process a verified California consumer privacy request within 45 days of receiving the request. If we require more time, we will inform you of the reason and extension period in writing. Please note that requests are subject to appropriate verification before processing.

XI. Your Privacy Preferences

Mainshares may provide you the opportunity to exercise certain preferences with respect to your Personal Information, such as accessing, updating, deleting, and exporting Personal Information, by logging into your account profile or by making a request to: support@mainshares.com.

Mainshares may, in its discretion, process such requests as a courtesy, subject to appropriate prior verification.

XII. Children’s Data

Mainshares recognizes the sensitivity of Personal Information concerning children under the age of majority (“Minors“). Our websites and Services are not marketed to Minors and we do not knowingly solicit or collect Personal Information from Minors. If you believe that a Minor has created an account or disclosed Personal Information to us, please notify us immediately at support@mainshares.com.

XIII. Main Street Securities LLC

Some of your personally identifiable information and other details will be shared with both the issuer of the assets and any buyer of your sell request for the purpose of concluding any transaction. For more information, please visit the Main Street Securities LLCTerms of Service.

XIV. Information Security

We take reasonable measures to protect our systems from harm and to safeguard the confidentiality, integrity, and availability of your Personal Information. Our efforts include implementing appropriate physical, technical, and administrative controls to ensure a level of security commensurate with the risk, in particular, to protect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored, or otherwise processed.

XV. Breach Notification

If your Personal Information is the subject of a data breach under applicable law or regulation, we will take appropriate action, including providing you with notice, as such law or regulations may require.

XVI. General Inquiries and Updates

For inquiries about this Privacy Policy, or to make a request or file a privacy complaint, please contact us at support@mainshares.com or at:

Mainshares LLC

Attn William Fry

1201 E Cesar Chavez

Austin, TX 78702

This Privacy Policy may be updated from time-to-time, so please check back regularly for updates.