Privacy Policy

Effective Date: 22 February 2024

PoliCapital (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you interact with our investment management services, websites, and other associated services (collectively referred to as the “Services”). By accessing or using our Services, you consent to the collection and use of your information as described in this Privacy Policy.

Information We Collect

We may collect personal information from you in a variety of ways, including, but not limited to:

• Information You Provide Directly: When you engage with our Services, such as opening an account, completing forms, or communicating with us, you may provide personal information such as your name, contact details, financial information, social security number, investment preferences, and other relevant details.
• Information from Third Parties: We may receive information about you from third parties, including financial institutions, service providers, or publicly available sources, to assist us in providing our Services.
• Automatically Collected Information: We may automatically collect certain information about your device and usage of our Services, such as your IP address, browser type, operating system, and browsing activity, through cookies and other tracking technologies.

How We Use Your Information

PoliCapital uses your information to:

• Provide Investment Services: Manage your investments, execute transactions, and offer personalized financial advice based on your goals and risk tolerance.
• Compliance and Due Diligence: Comply with legal obligations, perform identity verification, conduct risk assessments, and prevent fraud and other prohibited activities.
• Communication: Send you updates, newsletters, and other information related to your account and our Services. We may also use your information to respond to your inquiries and provide customer support.
• Service Improvement: Analyze usage trends and feedback to enhance the performance, security, and functionality of our Services.
• Marketing: With your consent, we may send you information about products, services, or events that may be of interest to you.

How We Share Your Information

We may share your information in the following circumstances:

• With Service Providers: We may share your information with third-party service providers who assist us in operating our business, such as custodians, compliance firms, technology providers, and other vendors. These parties are contractually obligated to protect your information and use it only for the purposes we specify.
• With Affiliates: We may share information with our affiliates for business purposes, including the offering of products and services that may be of interest to you.
• Legal Obligations: We may disclose your information to comply with legal or regulatory requirements, such as responding to subpoenas, court orders, or other lawful requests by public authorities.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.
• With Your Consent: We may share your information with third parties if you provide us with your explicit consent.

Data Security

PoliCapital takes the security of your information seriously. We implement industry-standard security measures to protect your information from unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

Your Choices and Rights

• Access and Correction: You may request access to the personal information we hold about you and request corrections to ensure its accuracy.
• Opt-Out: You may opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our emails or by contacting us directly.
• Data Deletion: You may request the deletion of your personal information, subject to certain legal or contractual obligations.

Cookies and Tracking Technologies

We may use cookies and similar tracking technologies to enhance your experience with our Services. You can control the use of cookies through your browser settings, but please note that disabling cookies may affect the functionality of our Services.

Children’s Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information.

International Transfers

PoliCapital operates globally and may transfer your personal information to countries other than the one in which you reside. When we transfer your information internationally, we take appropriate steps to ensure that your information is protected in accordance with this Privacy Policy and applicable laws.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated policy on our website and updating the effective date. Your continued use of our Services after any changes constitutes your acceptance of the revised Privacy Policy.

Contact Us

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us.