Privacy Notice

What we collect

This website has no forms, accounts, cookies, advertising or analytics trackers. We collect personal data only in these cases:

• When you email or call us: your name, contact details, the company you represent and whatever you choose to tell us.
• When you apply to invest: identity and company documents, ownership details, source-of-funds information, tax details and wallet or bank details. These are collected outside this website, as set out in the relevant onboarding documents. Some of this information is required by law; if you do not provide it, we cannot accept your investment.
• When you load a page: your browser sends technical data such as your IP address, browser type and the page requested. Our hosting and network providers process this to deliver the site and protect it from abuse.

How we use it

• To reply to you and to manage our relationship with you.
• To check whether you are eligible to invest, and to carry out identity, anti-money-laundering and sanctions checks that the law requires of us.
• To run the pools you invest in, including subscriptions, redemptions, reporting and payments.
• To keep records we are legally required to keep, and to meet requests from regulators and authorities.
• To operate and secure our website and systems.

We do not sell personal data, and we do not share it with others for their own marketing.

Consent

By giving us personal data, you agree that we may use it for the purposes above. You can withdraw your consent at any time by writing to us. Withdrawal does not affect use that has already taken place or use the law allows without consent, and it may mean we can no longer provide some services.

Who we share it with

We share personal data only as far as each purpose needs:

• Service providers that support our business, such as email, hosting, network and document providers.
• Compliance providers that check identity and screen against sanctions and similar lists.
• Administrators, custodians, banks, auditors and legal advisers involved in running the pools.
• Regulators, courts and law enforcement where the law requires it.

These parties may only use the data for the work we ask them to do.

Blockchain data

Transactions on public blockchains, including wallet addresses, are visible to anyone and cannot be changed or deleted by us. Where we know which wallet is yours, we keep that link private.

Transfers to other countries

Our team and providers work in several countries, so personal data may be stored or processed outside the British Virgin Islands and outside your own country. We transfer it only with appropriate safeguards or with your consent.

How long we keep it

We keep personal data only as long as we need it for the purposes above or as the law requires. Records from identity and anti-money-laundering checks are usually kept for at least five years after the relationship ends.

Access and correction

You can ask whether we hold personal data about you, what it is, how we use it and who we have shared it with, and ask us to correct anything that is wrong, by writing to [email protected]. We may need to confirm your identity first, and we aim to respond within 30 days. Please also tell us if your details change.

Security

We limit access to people who need it and use encrypted connections and reasonable safeguards. No system is completely secure, so please do not send identity documents by ordinary email unless we ask you to.

Questions and complaints

Questions, requests or complaints about personal data can be sent to [email protected]. If you are not satisfied with our reply, you may contact the Office of the Information Commissioner of the British Virgin Islands or the data protection authority where you live.

Changes

If we change this notice, we will update the date at the top. If a change materially affects how we use data you have already given us, we will tell you.