Privacy Policy

Version 202411127•December 9, 2024

1. Introduction

Privacy is very important to Forge, and we appreciate the trust you place in us when you use our services. Forge has a mission to foster safe, secure and trustworthy transactions in shares and other securities of non-public companies, as well as other alternative assets (the “Transactions”). Doing so requires a commitment to the privacy of our community.

This Privacy Policy applies to both information that is unique to you and may be used to identify you (“Personal Information”). This Privacy Policy describes the policies and procedures of Forge Global, Inc. and its subsidiaries and affiliates (collectively, the “Forge Group,” “Forge,“ “us,” “we”) regarding the collection, use, processing, storage and transfer of Personal Information concerning individuals who (i) visit the Forge website at forgeglobal.com and related websites, and the websites of the other Forge Group companies (together, the “Sites”), as well as the software, applications and platforms, marketplace, trade sheet, and other functionality and services available on the Sites (collectively with the Sites, the “Services”), (ii) obtain any other products and services from a Forge Group entity, or (iii) otherwise interact with us. Please note that this Privacy Policy does not apply to our processing of information about job applicants, employees or contractors.

Please note that certain details of this Privacy Policy may depend on whether you deal with us through an intermediary, directly as an investor, or whether Forge provides Services to your employer, advisor or fund or trust manager. In addition, some of Forge’s Services may have a different or additional privacy policy which may be made available to you if you choose to use those Services. If you are using the Services on behalf of an organization or a client (such as a fund or holding company you may manage or advise, a trust, or a joint account), this Privacy Policy is nevertheless personal to you as an individual, and does not apply to that organization, entity, or client or any information relating to that organization or client.

We will post any updates to this Privacy Policy on this page. From time to time, it may be necessary for you to supply us with further information, including Personal Information, in connection with the Site and the provision of the Services. Failure to supply such information may result in you being unable to use the Site or Services. If at any time you do not agree with this Privacy Policy, please discontinue your use of the Site or Services.

If you are a California resident, you may be entitled to additional disclosures and rights. Please see our Notice to California Residents.

If you are an individual located in a European Economic Area (EEA) member country or the United Kingdom, you may be entitled to additional disclosures and rights. Please see our Notice to European Individuals.

2. The information we collect and how we collect

In the course of operating the Services, Forge Group collects or receives the following types of information, which may include personal information:

Your name, address(es), email address(es) and phone number(s)
As applicable, your bank account information, money transfer instructions, age / date of birth, social security number, taxpayer ID number, driver’s license number or federal employer ID number.
Gender/sex, height and weight.
Occupation, employment information, income information.
Citizenship and residency information.
Account and identity information with respect to funds transfer accounts.
Financial information with respect to your investment objectives and means, including information about your wealth and financial situation, equity compensation and prior investments.
Service usage and Transaction history (including among other things bids, asks, negotiations, failed, abandoned, rejected, and otherwise uncompleted Transactions), as well as records of your communications with Forge and customer service requests. When you list, bid, ask, or otherwise indicate an interest in a Transaction, we provide information about your availability and offers, in anonymized form except as described below, unless you agree otherwise.
Information requested or required by regulatory or governmental authorities or law enforcement bodies.
In connection with certain Transactions, we gather documents pertaining to your ownership of Stock if you are a shareholder, including any documents you choose to upload. The types of documents we ask for include employment, stock purchase, option, and vesting agreements you may have with the company that issued your Stock, as well as company-related documents that may be considered confidential. We also keep records of the Transactions and Transaction documents. We may also have, or solicit, applicable documents from the issuer of the Stock, or from third party reporting services.
Information about your affiliation with the issuers of Stock you may own or purchase, or with any organizations, securities professionals, entities, or clients on whose behalf you are using the Services.
Behavioral and marketing information such as your interests, and your public social media presence.
If you invite others to use Forge, we may retain Personal Information related to your referral.
We also automatically collect information from your computer, browser, phone, or other devices and software used to access the Services using cookies and other tracking technologies, and log this information in log files. This information includes among other things your device ID, ISP, IP address, user IDs and access tokens for third party sites such as AngelList, Facebook, and LinkedIn, information you have authorized a third party to share, and any information you have made public on those services. For more information about how we use cookies and other tracking technologies see Section 7 below.

We may collect information by asking you to enter information (including Personal Information) into forms, by observing your account activity and usage of the Services, by logging your access and activity on the Site, by your uploading of documents, and via third party information providers that, among other things, provide background checks to verify your identity, creditworthiness, and your eligibility and suitability to participate in Transactions. Third party information providers include, among others: credit reporting agencies, social media sites, our affiliated entities, fund administration partners, advertising and marketing platforms, data brokers and other data sources, and compliance service providers.

If you register or use the Services through a third-party site or application such as AngelList, Facebook, or LinkedIn, or link your Forge account to those sites and applications, we may collect Personal Information from them. We may also collect Personal Information by direct communication with you and others by telephone, in person, and by online or electronic messaging means both on-Site and through off-Site services.

3. Cookies and similar technologies

When you access the Site or Services, we and certain information providers may place cookies, pixel tags, web beacons, page tags, or other data-gathering and transmitting tools or files (collectively, “Cookies”) on your device. These Cookies help us give you the best experience, perform analytics, analyze traffic, recognize you as a user, customize and personalize the Services, study and improve our offerings, collect information about your device and software in order to improve Site performance or prevent fraud. The information collected through Cookies may include your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to identify your browser or your account (including, for example, a persistent device identifier or an Ad ID), and other similar information. For more information about the Cookies on our Services, please visit our Cookie Policy.

We also work with third-party partners to employ Cookies and analytical tools, including the application of statistical modeling tools, that permit us to recognize and contact you across multiple devices, this includes the site from which you came and the site to which you are going when you leave our services, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, and other actions you take on the Services. We may collect this analytics data using third-party analytics tools such as Google Analytics. To learn more about the use of Cookies by Google for analytics and to exercise choice regarding those technologies, please visit the Google Analytics opt-out page.

4. Why we collect personal information

We collect Personal Information from and about you to:

Create a user account to use parts of our Services, maintain your user profiles and otherwise enable and facilitate your usage of Forge’s Services or as is necessary for your use of the Site and the provision of the Services.
Analyze and improve our business.
Correspond with you, including to fulfill your requests, provide you with information that you request or otherwise respond to your inquiry.
Help you discover, bid for, agree to, close, and otherwise participate in Transactions, as well as buy, sell, and otherwise enter into and service the securities and contracts that are issued as part of the Transactions, including but not limited to, enrolling you as a client of our affiliated brokerage(s) in connection with a Transaction.
Assure us, and parties to the Transactions, of the valid issuance, ownership, vesting status, transferability, and other attributes of securities issued by third party private companies (the “Stock”).
Verify your identity, your status as a professional investor, an accredited investor or qualified purchaser (or other qualifications), if applicable, process diligence checks, and establish your eligibility and suitability for being a member of the Forge community.
If you are using the Services on behalf of an entity, organization, or client, to verify your affiliation and that you are authorized to do so.
Setup and maintain accounts for sending and receiving funds and for depositing, holding and transferring securities.
Facilitate your and our compliance with various laws, regulations, and industry oversight pertaining among other things to banking, financial information, securities transactions, money laundering, terrorism, and “know your customer” rules promulgated by, among others, applicable government and regulatory bodies.
Personalize your experience and customize content relevant to your interests, including but not limited to advertising and marketing on the Services, through email, social media channels, third-party sites, or on other devices you may use.
Send you important information regarding the services, such as certain changes to our terms, conditions, policies, and/or other administrative information. Because this information may be material to your use of the services, you may not opt-out of receiving such communications.
To inform you of products, programs, services, and offers that we believe may be of interest to you, including, without limitation, sending you our newsletters.
Provide you with information about, and solicit your further participation in, the Services (which may include research and development purposes and direct marketing activities and/or the transfer of your Personal Information to third parties for their direct marketing purposes).
Study, test, and improve the Services, and the overall user experience using the Services.
Help maintain the safety, security, and integrity of our service, technology assets, and business.
Detect, prevent and address technical issues with the Services.
Offer customer support, technical support, maintenance, and product development.
To respond to law enforcement requests and as permitted by applicable law, court order, or governmental regulations and enforce our corporate reporting obligations and our Terms of Use, or to comply with applicable laws.
Protect against fraud, Site misuse, privacy and security breaches, securities and other legal and regulatory violations, and to fulfill and enforce agreements reached with you and others.
For purposes disclosed at the time you provide your personal information or as otherwise set forth in this Privacy Policy.

In an ongoing effort to better understand our Services, we might analyze your information in aggregate or de-identified form in a manner such that the end-product does not uniquely identify you or any other user of the Services. As a result, aggregate and de-identified information is not Personal Information subject to terms of this Privacy Policy.

5. Onward transfer of personal information

Like any company, we may share Personal Information that we have collected for the purposes described above with our affiliates and the following third parties (whether located within or outside your jurisdiction):

The other party or parties to a prospective or actual Transaction through the Services.
Intermediate entities such as funds and “special purpose vehicles” that handle securities pools on behalf of Forge or on their own account, as well as the organizers, managers, and fund advisers of these entities or other parties in order to complete, service and enforce the terms of a Transaction or contemplated Transaction.
If you become a security-holder or otherwise enter into a Transaction with a third party company, that company will have Personal Information about you, and subject to their own privacy policy, may be required to disclose that information to their own investors, board, and officers, and shareholders.
In the event of a reorganization, restructure, sale of a business unit, asset sale, merger with another company, public or private offering of our stock, creation of a subsidiary or a parent holding company, creation of a trust or other affiliated entity or other corporate transaction affecting the Forge Group, or our entry into negotiations to do the same, we may share your information (which may include Personal Information) with other parties to those transactions and such parties’ advisors and representatives on a need-to-know basis under assurances of confidentiality. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
We may create, acquire, or otherwise partner with parent, subsidiary, or affiliate business entities, trusts, or other business entities for purposes of offering the Services, issuing and holding securities, brokering and issuing securities, and servicing any notes or other instruments relating to Transactions, who may use the Personal Information under and consistent with the terms of this Privacy Policy.
If we are under a subpoena, court order, investigation, audit, reporting requirement or other legal or regulatory obligation, we may be required to disclose Personal Information as a matter of legal or regulatory process to any local or foreign regulatory, governmental, tax, law enforcement or other agencies or authorities for the purposes of complying with any law, rule, regulation or guideline.
Any affiliate, adviser, contractor, agent or third party service provider (including but not limited to affiliated broker-dealers, financial institutions and payment providers) who provide us with services relating to administration, telecommunications, payment, clearing, audit, accounting, risk management, credit, legal, compliance, operations, sales and brokerage, marketing, relationship management, securities management, information technology, records and data storage, performance measurement and compilation and analysis in connection with our provision of the Site and Services and our operations.
Our service providers who provide us with security, fraud prevention, advertising and marketing technology, information technology, site analytics, site maintenance, software development, electronic signatures, identity verification and other Site and service features, provided that all such parties will be under confidentiality duties to protect and not share any Personal Information we give them.
Our affiliated broker-dealers in order to enroll you as their client. Please note that these brokerages may have their own privacy policies and client agreements, which they will disclose to you at the time of your enrollment and participation.
Our affiliated custodial organizations in order to enroll you as their client. These organizations may have their own privacy policies and client agreements, which they will disclose to you at the time of your enrollment and participation.
Further, per the terms of the Transactions and other agreements you may enter into, Forge may setup or contract with third parties to service, pool, and otherwise manage the securities that are the subject of the Transactions.
To any other third parties or with the public at your direction or instruction, or with your approval
Any other person under a duty of confidentiality to the Forge Group or its affiliated entities that have undertaken to keep such Personal Information confidential.

6. Online Privacy Choices

Online Advertising

We permit our trusted business partners and third-party advertising companies (including ad servers, ad agencies, technology vendors, or providers of sponsored content, collectively “ad partners”) to collect your browsing information and numerical identifiers associated with your browser or device to provide ads on our behalf that are tailored to your interests. These ads may appear on our Services and on other third-party websites. Using cookies, our ad partners collect data from a particular browser or device about a user’s web viewing behaviors over time, across unrelated websites, and in some cases combine such data with data collected from other browsers or devices associated with the same user or household and use such data to predict user preferences and to deliver advertisements to that user which are calculated to target that user’s predicted preferences across devices. If you take steps to block advertising cookies or opt out of interest-based advertising, note that this does not mean that you will no longer receive ads from Forge, as these ads are only one form of digital advertising. Throughout our online advertising practices we support the self-regulatory principles of the Digital Advertising Alliance (“DAA”).

Privacy Preferences

You have some choices regarding how we use your Personal Information. Under certain circumstances, you have the right to do the following:

Accessing, Correcting and Updating Your Information: When you set up an account as a Site Member, you can access and update your Personal Information by signing in on our Services, and changing your choices and settings. If you have questions about reviewing, changing, or deleting your information, you can contact us directly using the contact information below. We may not be able to change or delete your information in all circumstances.
Update Communications Preferences: To opt out from direct marketing emails at any time and without charge via the “unsubscribe” links on any marketing message sent to you, via your account settings if you are a Site Member, or by contacting us directly. You will not be able opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the services, technical and security notices).
Non-Affiliate Data Sharing: You may prevent us from sharing the Personal Information we have collected about you with non-affiliated third parties in certain circumstances. You may opt out of our sharing of the Personal Information that we have obtained from third parties, such as your credit reports, with our affiliates. You may also opt out of our sharing of Personal Information about you to non-affiliates so that they can market to you. You may not, however, limit our sharing of Personal Information for the purposes of providing the Service, our everyday business purposes, our own marketing, or for joint marketing efforts with other financial companies. To opt out, you can contact us directly using the contact information below.
Cookies and Online Advertising: Most browsers accept Cookies automatically, but you can block or delete Cookies at any time to prevent the collection of your browsing information for purposes of delivering interest-based ads and tracking visitor behavior. You can block or opt out of Cookies by adjusting settings within your device or browser. For instructions, check your browser’s technical information. You can also find options for restricting Cookies placed by some of our ad partners, on the DAA’s opt-out page or the by using the NAI’s opt-out tool. Please note that blocking or deleting Cookies could affect your ability to fully use the Site and Services.

If you are a resident of California, you may have additional rights as set forth in our Notice to California Residents.

7. Record retention

We may retain or delete your Personal Information according to our internal data retention policies as permitted by applicable laws and regulations, even after you no longer use the Site and Services or terminate or deactivate your account or your relationship with Forge, among other things for backup, archival, contract enforcement and dispute resolution, auditing, and regulatory compliance purposes. Note, also, that securities law and regulations, among other things, may require that we keep an archival / recordkeeping copy of some or all of your Personal Information, that we provide such information to regulatory authorities, and that removing, deleting, erasing, suspending processing of, or withdrawing consent with respect to your Personal Information may result in our no longer being able to provide you the Services.

8. Age restrictions

The Site and Services are directed at and intended solely for adults according to the age of majority and other laws of their jurisdiction. We do not knowingly collect any information from anyone under the age of 18 or allow them to use the Site or Services. If you learn that we may have inadvertently collected any such information, please contact us immediately for a resolution.

9. Other sites and services

Forge may refer you to third parties, via links from its Site or Services, communications from Forge, or otherwise. These include among others any banks, payment processors, electronic signature services, brokerages, educational and informational sites, and transfer agents. Forge is not responsible for the privacy policies and practices, performance, or terms of use and other contracts offered by these third parties, and does not endorse, provide, or provide any warranties with respect to any content or services they offer you. Please remember that when you go to another website or other service, that service may have its own privacy policy that applies in place of or in addition to ours.

10. How we protect your personal information

Forge has developed security controls designed to maintain the confidentiality, accuracy, and security of the Forge community’s Personal Information, to honor our clients’ integrity, respect the trust the Forge community places in us, and for purposes of compliance.

We protect Personal Information by using software, physical safeguards, and internal procedures, in compliance with applicable laws and regulations. This includes using secure servers, encryption, and locked facilities as applicable. We maintain access policies designed to limit access to Personal Information to those who need to know as part of the Services, and education and training for employees on the importance of confidentiality. We have a policy designed to require companies that work with us to protect Personal Information as well.

We ask you to help by taking reasonable precautions to protect your own files, use secure passwords, and generally exercise due care with any sensitive information about yourself or other people.

No security system is completely secure or without risk. If you become aware that any Personal Information we have appears to be inaccurate, and you are unable to correct it yourself from your user account, you may contact us as described below. You may also contact us anytime if you have questions regarding your Personal Information, the Services, or any other matter.

11. Contact us

Forge is the contact for all matters related to this Privacy Policy, including without limitation, any complaints or requests for access to and correction of your Personal Information.

You may contact Forge, attention to Legal Department, at 4 Embarcadero Center, Fl. 15, San Francisco, CA 94111, USA, or [email protected].

All non-US clients, including those in the European Union and Asia-Pacific, should use the above contact addresses for any questions, issues, or requests regarding their Personal Information and this Privacy Policy. If you believe we have not adequately responded to any request or resolved any complaint, you may have the right to contact your local governmental or regulatory body to file a complaint.

12. Policy changes

This Privacy Policy may be amended from time to time at any time. For the purposes of any such amendments, our posting of a revised version of the Privacy Policy, with an updated version date, is to be considered adequate notice to you of the amendment. Any revised version will be effective as of the time posted to the Site, or otherwise noticed to you. Therefore, you should review this Privacy Policy periodically. We may require you to affirmatively assent to any revised version of this Privacy Policy as a condition for continued use of the Site or Services or as required by relevant laws or regulations.

13. Transfer of personal information between jurisdictions

Our collection, holding, processing or use of your Personal Information in accordance with this Privacy Policy may (whether in whole or in part): (i) take place outside of the jurisdiction in which you reside, or (ii) be controlled by a party whose principal place of business is located outside of your current jurisdiction, where there may not be in force any data protection law which is substantially similar to, or serves the same purposes as, the data protection laws in your current jurisdiction.

Important Notice for Individuals of the European Economic Area, United Kingdom, and Switzerland

Forge complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), as set forth by the U.S. Department of Commerce. Forge has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Information received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Forge has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal Information received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Further, the following entities or subsidiaries also adhere to the DPF Principles: Forge Global Advisors LLC, Forge Securities LLC, Forge Trust Co., and Forge Data LLC.

Forge is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Complaints per the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles, Forge commits to resolve complaints about your privacy and our collection or use of your Personal Information transferred to the United States pursuant to the DPF Principles. European Union, UK, or Swiss individuals with inquiries or complaints regarding this notice should first contact Forge at [email protected].

Forge has committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to an independent dispute resolution mechanism, JAMS Data Privacy Framework (DPF) Dispute Resolution. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See DPF Annex 1 at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

Onward Transfer to Third Parties

In the event that we disclose your Personal Information to third parties to perform certain business-related services on our behalf as our “agents” (as such term is utilized under the Data Privacy Framework), we will do so only for limited and specified purposes consistent with any notice provided to you or your choices regarding processing and disclosure. These companies perform services at our instruction and pursuant to contracts which require they provide at least the same level of privacy protection as is required under the Data Privacy Framework and notify us if they are no longer able to provide such protections, at which point we will take reasonable remedial steps. We may also disclose Personal Information to our affiliates in order to support marketing, sale, and delivery of any services, or other business operations as disclosed in this Privacy Policy.

Forge’s accountability for Personal Information that it receives under the DPF and subsequently transfers to a third party is described in the DPF Principles. In particular, Forge remains responsible and liable under the DPF Principles if third-party agents that it engages to process the Personal Information on its behalf do so in a manner inconsistent with the Principles, unless Forge proves that it is not responsible for the event giving rise to the damage.

In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Option to Limit Certain Onward Transfers to Third Parties

Individuals have the opportunity to opt-out of sharing of their Personal Information with third parties other than our agents or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your Personal Information under the Data Privacy Framework, please submit a written request to [email protected] indicating as such. Please allow us a reasonable time to process your response.

We will not disclose your sensitive Personal Information to any third party without first obtaining your opt-in consent.

Your DPF Rights

Upon request to [email protected], we will confirm whether we are processing your Personal Information pursuant to the DPF and provide you with the data within a reasonable time. You also have the right to request that we correct, amend, or delete the Personal Information processed pursuant to the DPF where it is inaccurate or has been processed in violation of our privacy disclosures to you, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries and requests.

Personal Information Retention

We will retain the Personal Information processed pursuant to the DPF in a form that identifies you pursuant to our retention policy described above. We may continue processing such Personal Information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of our privacy disclosures. After such time periods have expired, we may either delete your Personal Information or retain it in a form such that it does not identify you personally.

How We Protect Your Data

We will implement reasonable and appropriate security measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data. Please note that we cannot guarantee absolute security of your Personal Information given the inherent limitations of collecting and storing information through systems connected to the internet.