Privacy Policy, Data Oversight & Collection, GDPR Compliance Review 

This Privacy Policy (“Privacy Policy”) describes how we 'Cap Hedge Ventures, Inc' collect, use, disclose and transfer the information that you provide to us or that we collect about you when you access and use our website at https://www.fintrx.com (the “Website”), or our FINTRX products and services (the “Services”), or use our Services provided through the Website (“Online Services”).

Information we gather on you & how it is used:
A. Visitors
While parts of the Website may be used without registration, your use of the Online Services and much of the Website content require registration. You may choose not to provide us with any Personal Information. However, you will not be able to use those portions of the Website that require your Personal Information and registration.

If you use our Website as a visitor without registering or sending us inquiry information, the only information we collect will be automatic tracking information (please see Automatic Information We Collect About You in Section 2 below).

B. Registered Users and Prospects
Registered users are those visitors to our Website who seek to register for our reports or other limited free offerings on the Website.

By prospects, we mean those individuals at companies who have shared their contact information with us, whether it has been through a form on the website, from information collected at a trade or marketing event, or have reached out directly to us.

For both prospects and registered users, we may collect information that may personally identify you, including, but not limited to your contact information including name, job title, organization, address, e-mail address, or phone. As well, we may collect general information relating to your business objectives, user preferences, and Website and event participation information.

For registered users only, we may also collect information using cookies that helps us understand what you are viewing and responding to on our website once you have already provided us with your Personal Information. Once your activity rises to a point that indicates to us that you might have a reasonable interest in our information, our internal CRM system will alert our sales team to reach out to you.

We use the Personal Information to manage our relationship with you including responding to your questions and social media communication, providing you with the specific Services you select, if applicable, and providing you with information about our company and Services.

If no longer wish to receive emails from us, you may opt-out of receiving them at any time by following the instructions included in the link at the bottom of each sent email, (OR) by contacting us at sales@capitalhedge.net.

C. Inquirers
We may also collect information that personally identifies you when you e-mail with us or otherwise correspond with us (for example, when you send us e-mail communications or send letters to us or otherwise make inquiries on our website) or when you use the “Contact Us” option on our website. Any such information you provide us will be used to respond to your inquiries.

D. Profile Data Subjects
As part of our Services, we collect, use, transfer, and distribute publicly-available data on global investors for our business clients and partners in the private wealth, institutional and finance industries, and educational institutions.

INFORMATION WE AUTOMATICALLY COLLECT FROM YOU
Even if you do not register on www.capitalhedge.net, we collect information about your use of our Website in order to further personalize the content and information we present to you.

A. Cookies
“Cookies” are small computer files that are transferred to your computer, mobile device or IPad that contain information such as your user ID, user preferences, the pages you’ve visited and the activities you’ve performed while using the Website. We use “session cookies” to customize your experience on the Website and, if you create a password, we use “persistent cookies” to store your password so you do not have to re-enter it each time you visit the Website. We do not link the information stored in cookies to any of your Personal Information you submit while on the Website. You have the right to choose whether or not accept cookies. You may block cookies or delete cookies from your browser; however, by disabling cookies, you may not have access to all of the features of the Website. You also have the option to browse our website using free cookie blockers like Ghostery or the “Incognito Mode” function in Chrome. Some of our business partners also use cookies to provide us with anonymous data and information regarding your use of the Website. We do not have access or control over these cookies.

C. Traffic Data
We automatically track and collect the following categories of information when you visit our Website: (1) Internet Protocol (IP) addresses; (2) domain servers; (3) computer, device and connection information, such as browser type and version, operating system, mobile platform and unique device identifier (UDID) and other technical identifiers; (4) Uniform Resource Locator (URL) click stream data, including date and time stamp, referring and exit URLs, search terms you used and pages you visited or search for on the Service; (5) for location-aware Services, the region, city or town where your device is located in order to provide you with more relevant content for where you are in the world; (5) referring source which may have sent you to the Website; and (6) other information associated with the interaction of your browser and the Website. If you are using a mobile or other device to visit the Website, we may collect hardware information related to the device about you.

If you do not wish to opt-out of information automatically collected by us, please contact us at support@capitalhedge.net.

LINKS TO OTHER WEBSITES
The Website may contain links to third party websites to which Cap Hedge Ventures has no affiliation. Cap Hedge Ventures does not share your personal information with those websites and is not responsible for their privacy practices. 

DISCLOSURE OF YOUR INFORMATION
By registering with our Website, you agree that we may share certain categories of information we collect from you in the ways described in this Privacy Policy. We share Personal Information and Traffic Data with our business partners who assist us by performing core services (such as website hosting, data storage and security) related to our operation of the Website and/or by making certain Services available to our users. Those business partners shall be bound to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your contact data and other Personal Information to carry out their specific business obligations to and to provide you with Website related services.Cap Hedge Ventures does not share, sell, rent or trade your Personal Information with any third parties for their promotional purposes.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights or property, to mitigate our liability in an actual or potential lawsuit, to comply with a judicial proceeding, court order, or legal process served on our Website, to enforce this Privacy Policy or our Terms of Use or any other agreement in place between you and Cap Hedge Ventures, or to investigate and prevent unauthorized transactions or other illegal activities.

RETENTION PERIOD
Cap Hedge Ventures will retain Personal Data about you for the period reasonably necessary to fulfill the purposes described in this Privacy Policy and consistent with its retention policy and as required or permitted by law.

FOR EEA CITIZENS
European Union (EU) data protection law regulates the transfer of EU customer personal data to countries outside the European Economic Area (EEA), which includes all EU countries and Iceland, Liechtenstein, and Norway.

A. Basis for Processing
Cap Hedge Ventures processes data under this Privacy Policy based on (a) consent of the user as a condition of accessing this Website; (b) the necessity of the data for entering into a contract for Services; and/or (c) the necessity of the data for performing the Services. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR DATA IN ORDER TO ACCESS AND USE THE CAP HEDGE VENTURES WEBSITE (WWW.CAPITALHEDGE.NET), PLEASE DO NOT USE, OR ENGAGE WITH, CAP HEDGE VENTURES WEBSITES.

C. Cross Border Transfer
Data centers hosting your data under this Privacy Policy are located within the United States. Accordingly, as an EEA citizen, in order to access the Services and content provided byCap Hedge Ventures, your data may be transferred outside of the EU. You consent to the cross-border transfer of your data in order to receive access to the Cap Hedge Ventures website and/or Services.

The EU Standard Contractual Clauses (commonly referred to as the “Model Clauses”) are standardised contractual clauses used in agreements between service providers (such as Cap Hedge Ventures) and their clients or partners to ensure that any personal data leaving the EEA will be transferred in compliance with EU data-protection law and meet the requirements of the EU Data Protection Directive 95/46/EC, or its successor legislation, the General Data Protection Regulation (EU) 2016/679 (GDPR).

11. HOW YOU CAN ACCESS, CHANGE OR SUPPRESS YOUR PERSONAL DATA

If you would like to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been provided to us, you may make a request by contacting us using the information providing in the Contact Information for Cap Hedge Ventures below. For your protection, we may need to verify the request is valid. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law.

If you completely delete all such information, your account may become deactivated. Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that are pending.

CHANGES TO THIS PRIVACY POLICY
We reserve the right, at any time, to add to, change, update, or modify this Privacy Policy so please review it frequently. If we make a material change to our Privacy Policy, then we will notify you by email, here on this page, as well as by posting a notice on our website. In all cases, use of information we collect is subject to the Privacy Policy in effect at the time such information is collected. If you do not agree with any changes or modifications to the Privacy Policy, please do not continue using the Website. You will be deemed to have consented to any modification of the Privacy Policy when you use the Website after the effective date of the modification.

CONTACT INFORMATION
If you have any questions about this Privacy Policy, or your dealings with this website, or want to request access or changes to our handling of your data, or lodge a complaint, please contact us at support@capitalhedge.net or send mail to:

Cap Hedge Ventures, Inc
100 Ledgewood PlaceSuite 203
Rockland, MA 02370
United States of America
Attention: Data Privacy 

INFORMATION ON WHAT WE COLLECT ON OUR INVESTOR PROFILE SUBJECTS

1. WHO YOU ARE
You are privileged to fall within the wealthy class (direct family wealth or pooled family wealth) and/or have such public prominence that businesses and organizations want to seek you out to provide you with opportunities for investment or donation to your favorite charity or educational establishment. You are also a data subject whose personal data we have collected as part of our data intelligence gathering research as we deem it will be useful to our clientele. Because of your prominence and the amount of data we collect, it is not feasible to contact you individually to inform you of your rights under the EU Data Protection Directive 95/46/EC, or its successor legislation, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) if you are an EU or UK data subject. While the GDPR currently only applies to EU and UK citizens, we hope this notice will be helpful to all the data subjects who may be under other applicable data protection laws or may just want to know how we are processing their data and of their right to review and make corrections. Accordingly, we are providing this Notice to you on our website as written here.

2. WHO WE ARE AND WHO ARE OUR CUSTOMERS
We are an investor data intelligence research gathering company focused on single family office companies and multi family office companies, providing helpful, informative research on family offices to our business customers in the investment industry, and to non-profits and educational institutions (our “Customers”).

Our Customers are businesses and organizations that seek business relationships with you or seek to enhance a relationship that already exists. Our research is designed to help these Customers understand more about you, your general and investment interests and your inclinations: a) so that they can get a better sense of whether there would be a good fit between you and their offerings; b) to help them tailor their offerings and initial outreach so that they can better connect with you; and c) to generally enhance their offerings or communication with you so that your user experience is improved and personalized to meet your needs and expectations.

3. THE RESEARCH DATA WE COLLECT
For our investor research, we use data gathered directly from the investor, in addition to  publicly accessible sources including but not limited to:

Public Registers

Trade and Industry References

Professional Directories

Reliable print and broadcast media

Internet company websites (we do not use blogs or user-edited content)

Conference attendance information & speakers

The bulk of our research is focused on compiling this publicly available data on single and multi family office investors.

4. CATEGORIES OF DATA COLLECTED & STORAGE
The publicly-available data we collect on you relates to areas that our Customers would find useful in pursuing a business relationship with you.

In addition to providing your name and business contact information, we provide your biography, business and investment history, previous places of employment, potential investment areas of interest, past areas of investment, and general location information.

We do not collect any information such as religion, nationality, and political affiliations as paid out under Article 9 of the GDPR.

Upon collection, the data is stored in our database that is located on a secure server which is managed and secured by Amazon Web Services (AWS). We take appropriate technical and organizational measures to ensure that your data remains secure. AWS is a leading provider of cloud servers and prides itself on its state-of-the-art security. You can read more about its security practices at https://aws.amazon.com/security/.

Once the data collection is completed, we use it to prepare a commercially-available research offering we call a “investor profiles” that we sell to our Customers.

Our dossiers are distributed to our Customers via a written signed contract that requires that Customers a) use the investor profiles for lawful purpose; b) use the investor profiles for their internal business purpose only; and c) maintain the confidentiality of the investor profiles.

Accordingly, we do not broadly publish or disseminate the investor profiles to the public nor do we seek to use the information to embarrass you or harm your reputation. Our goal is to respectfully provide limited access of the investor profiles to a target business audience who can hopefully provide you with a service or offering that appeals to you.

6. LEGITIMATE INTEREST
As part of our obligation under the GDPR, we have performed a comprehensive review of our data processing activities pursuant to a privacy impact assessment and believe that our processing is justified based on the legitimate interests of our customers and our business; further that such interests are not overridden by your rights and freedoms, particularly given your resources, newsworthiness, and prominence when balanced against the restricted and respectful, narrowly-tailored use we make of your data.

7. RETENTION OF YOUR DATA
Since we are in the business of providing intelligence gathering research on the wealthy, so long as you meet our criteria, we will maintain your data in our secure database. Periodically, we will clean up our database and remove data and dossiers that no longer meet these criteria or that we no longer believe is useful.

8. INTEGRITY OF YOUR DATA
As indicated above, we employ a criteria process under our data gathering process that is designed to ensure the accuracy of the data. Despite these efforts, we cannot guarantee the accuracy of all our records. However, we do perform periodic review of the data and make updates when we identify or learn of error or needed updates. Much of the data we collect is historical and thus needs no updating.

9. ACCESS AND CORRECTION OF YOUR DATA
If you are located in the EU, UK or in a country that provides access and correction rights, we welcome your request to access, correct or update your data that we hold about you. You can request that we delete your information with respect to data that does not meet a lawful justification for processing as well. If you wish to exercise these rights, please contact us at support@capitalhedge.net, 'attention: data privacy'.

10. CHANGES TO OUR POLICY
We reserve the right to make changes to this Privacy Policy as needed to reflect our practices and/or to comply with the law.

11. MORE INFORMATION
Thank you for taking the time to read through all of this. If you have questions regarding this policy or privacy practices at Cap Hedge Ventures and our flagship product, The FINTRX Platform, or would like a copy of the information we hold on you, please contact us at support@capitalhedge.net with an attention to: data privacy

This Website Uses Cookies
We use necessary cookies that enable this website to function properly. We also utilize cookies to help analyze our traffic and better understand the content preferences of our users. In addition, we share information with our social media, advertising and analytics partners who may combine it with other information you have provided them or that they have collected from your use of their services. You consent to our cookies if you continue to use this website. If you wish to refrain from use of our cookies, please close out the website and send an email to: support@capitalhedge.net with an attention note of: cookie removal and we will remove any stored cookies we have on you within 24 hours of request.

GENERAL REQUEST OR CONCERNS

If you would like us to look into a specific action or request that is not outlined above, please send an email directly to: support@capitalhedge.net with a reference to your request and we will respond to you within 5 business days. As always, we will do our very best to meet any data or privacy concerns you may have and are committed to be lawful and transparent in our data collection and the use of said data. Thank you.