Coinful Capital is committed to processing personal information (“PI”), including sensitive personal information (“SPI”) in line with applicable privacy and data protection laws (please note that not all privacy laws define SPI such as Hong Kong, Canada and Singapore). Our offices are located in countries with laws governing the processing of PI. “Coinful Capital”, “we”, “us” or “our” means Coinful Capital SPC, and each of the direct or indirect subsidiaries or segregated portfolios of Coinful Capital (the “Coinful Capital Group”). Coinful Capital’s entity you contract with are the controllers of your PI. However, if your relationship with the Coinful Capital Group is in connection with an investment in a Coinful Capital segregated portfolio or you are unsure as to the nature of the relationship, Coinful Capital will be the controller. References to “you” or “your” refers to individuals whose PI is processed by Coinful Capital Group, including clients with direct or indirect relationships (such as those who invest through an intermediary); employees, contingent workers, officers, agents (together “Representatives”); and beneficial owners of an organization or entity in connection with:
This Privacy Notice sets out the purposes for which we collect, use and disclose (collectively “processing”) PI and how it is protected. It also sets outs individuals’ rights in relation to the processing of their PI. There may be additional terms, conditions and commitments that also govern how we collect, use and disclose your PI, which should be read in conjunction with this Privacy Notice.
PI we collect about you is information relating to an individual, which can be used either alone or with other sources of information to identify that individual. PI does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous. SPI is a sub-category of PI that includes PI relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data or tax and financial information. The nature of the information that we collect will depend on the our relationship with you. We categorize PI we process as follows (the PI listed for each category are non-exhaustive examples:
We collect PI in relation to you in a number of ways, including:
We may also create or derive PI such as creating records of your interactions with us, subject to applicable law. Unless we otherwise indicate that the provision of specific PI is optional, any PI we request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the PI requested, we may not be able to provide those products and services.
The below table sets out the purposes and basis for which we process PI.
To consider opening an account, or entering into a relationship at your request, including performing anti-money laundering, anti-terrorism, sanction screening, fraud and other due diligence checks
To deliver the services you have requested, including liaising with third parties and to provide access to our technology solutions services
To manage payments, fees and charges and to collect and recover money owed to us
To manage our relationship with you which will include notifying you about changes to our terms of business or this privacy notice
To interact with governmental or regulatory bodies or other competent national authorities
To detect or prevent fraud and/or other criminal activity and to protect our employees and assets
To manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, data hosting, managing our offices and other facilities
To invite you to take part in market insight or other events, or client seminars or similar events, and to manage your participation in them
To send you marketing (including by paper and electronic channels) communications and service updates.
In relation to vendor services:
To engage you or the organization or entity you work for as a new supplier, including performing anti-money laundering, anti-terrorism, sanctions, fraud and other background checks
To manage payments, fees and charges and to collect and recover money owed to us
Where we provide you access to our systems we need to manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, and data hosting
In connection with one or more of the purposes outlined in the section ‘Purpose and Legal Basis for Processing Your PI’ above, we may disclose PI in any jurisdiction to:
To provide global services and in the course of running our business, we may transfer PI to a location outside of the country where you reside or where services are provided to you or the organization or entity you work for, including Coinful Capital processing centers in Taiwan, Australia and Singapore. Although the country to which PI may be transferred may not have the same level of privacy and data protection laws, we apply the same level of security and organizational controls to the processing of PI wherever it is processed.
We require by contract that our third party service providers processing PI on our behalf to comply with Coinful Capital’s criteria for PI processing. If we transfer PI out of the EEA, we ensure a similar level of protection for your PI by ensuring the country to which the PI is transferred is considered by the EU Commission to provide an adequate level of protection, putting in place contractual clauses the EU Commission consider to provide the same level of protection. For third party service providers in the US, we may rely on the EU-US Privacy Shield certification.
We will not process your PI for marketing purposes if you have informed us you do not wish to receive marketing materials. You can request that we stop processing your PI for marketing purposes at any time by clicking on marketing opt-out links in any electronic marketing materials we send you, by making a request to your usual Coinful Capital contact or by using the contact details set out in the “Contact Us” section of this notice.
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.
We will process your PI for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defense of legal claims.
We use a range of physical, electronic and managerial measures to ensure a level of security appropriate to the risk of PI processing. These measures include:
The security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries the risk of access and interception. You should not send us any PI by open/unsecure channels over the internet. We endeavour to protect personal information but cannot guarantee the security of data transmitted to us or by us.
In certain circumstances you may have the following rights in relation to the processing of your PI:
You may exercise your rights at any time by using the details set out in the “Contact Us” section in this notice. To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection with you exercising your rights. We may need to request specific information from you to help us confirm your identity and ensure your right to access to the PI requested, or to exercise any of your other rights. This is to ensure that PI is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us to locate the PI processed in relation to you, including, for example, the nature and location of your relationship with us. We aim to respond to all legitimate requests within one calendar month. If we think it may take us longer than one calendar month, (such as where your request is particularly complex or you have made a number of requests), we will notify you and keep you updated. You will not be disadvantaged in any way by exercising your rights in relation to the processing of your PI.
Coinful Capital’s director’s office oversees compliance with privacy and data protection at Coinful Capital. If you wish to exercise any of your rights, or have questions concerning this notice, please contact:
Privacy and Data Protection
S Church Street,
George Town, KY1-1104, Cayman Islands
If you have any concerns or complaints about the way your PI is processed, please contact the directors at firstname.lastname@example.org.
You also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your PI has arisen.
This notice is not applicable to third party websites that we do not own or control, or to any third-party website where Coinful Capital may be displayed.
We may modify or amend this notice from time to time and you are advised to visit our website regularly to check for any amendments. Any material changes will be communicated to you through an appropriate channel, depending on how we normally communicate with you.
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