1. Who we are and how this policy applies
CONIM is a product of its parent company, which operates the service. In this policy, "CONIM", "we", "us", and "our" mean that company. Disclosure of the parent company is available upon written request to CONIM, 1259 El Camino Real, Unit #1218, Menlo Park, CA 94025.
We play two different roles, and which one applies decides who answers for the information:
- For information about our own customers, website visitors, and business contacts, we decide how it is used and this policy describes what we do.
- For the documents and deal information a customer uploads, and for the information about buyers that a customer's memorandum collects, the customer decides how it is used. We process it on the customer's behalf as a service provider. If your information is in a memorandum or you were invited to view one, the broker or advisor who uploaded it or invited you is the right person to contact first.
The service is intended for business and professional use by people in the United States who are at least 18 years old.
2. Information we collect
From customers who create an account:
- Account details: name, email address, sign-in credentials or single sign-on identifiers, and brokerage or company details and brand materials you add.
- Billing details: plan, payment history, and the card brand, last four digits, and expiry date. Full card numbers are collected and held by our payment processor and never reach our systems.
- Deal content: the documents, financial statements, tax returns, spreadsheets, photos, video, and text you upload for a deal, the story and memorandum generated from them, your edits, your answers to buyer questions, and your sharing settings.
- Usage records: actions taken in the app, AI runs and their cost, and support messages.
From buyers who are invited to a memorandum:
- Details the inviting customer enters about you: name, email address, and company.
- Your acceptance of the customer's confidentiality terms: the name you type, the date and time, and your IP address.
- Your activity in the memorandum: each visit, the sections you read and for how long, the questions you ask and the answers given, and the files you download.
From business contacts and prospects:
- Business contact details of brokers, advisors, and related professionals, such as name, firm, business address, business phone, business email, professional designations and awards, and website. We collect these from public sources, including professional association directories, state license records, and firms' own websites, and from service providers that supply business contact data.
- Your replies to us and your marketing preferences, including any request to stop hearing from us.
From everyone who visits our sites, automatically:
- Device and log information: IP address, browser and device type, pages requested, referring page, and dates and times.
- Cookies and similar technologies that are needed to keep you signed in and protect the service, described in the Cookies section below. We do not use advertising cookies or sell browsing data.
3. How we use information
We use the information described above to:
- provide the service: create accounts, process documents, generate memoranda and answers, host memoranda and data rooms, control access, and show customers their buyers' activity;
- take payments, send receipts, and manage plans, renewals, and failed payments;
- keep the service secure, prevent fraud and abuse, and enforce our terms;
- support customers and respond to requests;
- send service messages, and send marketing about CONIM to customers and business contacts, which you can opt out of;
- understand how the service is used and improve it, including by creating de-identified and aggregated information; and
- comply with the law and protect our rights and the rights of others.
4. Artificial intelligence
The service uses artificial intelligence models operated by a third-party provider to read uploaded documents, propose and draft the memorandum, and answer buyer questions from the memorandum. To do this, the content of uploaded documents and questions is transmitted to that provider for processing.
We do not use deal content in identifiable form to train artificial intelligence models, and we do not authorize our AI providers to use it to train their general-purpose models. We may create de-identified and aggregated information from deal content and from use of the service, meaning information that does not identify a customer, a business, a buyer, or any individual, and use it to analyze, improve, and develop our products and systems.
AI output can be wrong. Customers review and approve memoranda before sharing them, and buyers should not treat an AI-generated answer as verified.
7. How long we keep information
We keep account information for as long as the account is open and for a period afterward as needed for billing, tax, legal, and security purposes.
Deal content is kept while the customer's plan or listing period is active. When a subscription ends, a listing period expires without extension, or an account is closed, the memorandum goes offline. We keep the deal content for 30 days, after which we may delete it. Copies may persist in backups for a limited time before they are overwritten.
We may keep records of confidentiality acceptances, activity logs, and billing for longer where we or the customer may need them as evidence or where the law requires. Business contact details are kept until they are no longer useful or you ask us to remove them, and we keep a record of opt-outs so that we can honor them. De-identified and aggregated information may be kept indefinitely.
8. How we protect information
We use administrative, technical, and physical safeguards that are reasonable for a service of this kind, including encryption in transit, access controls, private links, and access limited to personnel and providers who need it. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Customers are responsible for protecting their sign-in credentials and for choosing who they invite.
9. Your choices and rights
- Marketing email: use the unsubscribe link in any marketing message, or write to legal@conim.io. We will stop sending marketing to that address. We may still send messages about an account or a transaction.
- Business contacts: if we hold your business contact details and you want them removed or corrected, write to legal@conim.io.
- Account information: customers can view and update most account information in the app, and can ask us to close an account and delete its content.
- Access, correction, and deletion: depending on where you live, you may have the right to ask what personal information we hold about you, to have it corrected or deleted, and to receive a copy. Send requests to legal@conim.io. We will verify your identity before acting and will not discriminate against you for making a request. You may use an authorized agent, and you may appeal a decision by replying to our response.
- Information in a memorandum: if your information appears in a customer's memorandum, or you viewed one as a buyer, we will refer your request to that customer and assist them in responding, because they control that information.
- Cookies: you can block cookies in your browser. Parts of the service, such as staying signed in, will not work without them.
We do not sell personal information or share it for cross-context behavioral advertising, and we do not use sensitive personal information to infer characteristics about people. We do not knowingly process the personal information of anyone under 18.
10. Children
The service is not directed to children, and we do not knowingly collect personal information from anyone under 18. If you believe a child has given us personal information, contact us and we will delete it.
11. Where information is processed
CONIM is operated from the United States and is intended for use in the United States. Information is processed and stored in the United States and in other places where our service providers operate. If you use the service from elsewhere, you understand that your information will be transferred to and processed in the United States, where privacy laws may differ from those where you live.
12. Changes to this policy
We may update this policy from time to time. The current version is always posted on this page with its effective date. If a change is material, we will give notice by email or in the service before it takes effect.
13. Contact
Privacy questions and requests should be sent to legal@conim.io, or by mail to CONIM, 1259 El Camino Real, Unit #1218, Menlo Park, CA 94025.