Privacy Policy

1. Definitions

• "Personal Data" means any information that can directly or indirectly identify an individual (as defined by GDPR, CCPA, and other applicable laws).
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• "User" or "Client" means any individual, entity, or institution interacting with our Services.

2. Data We Collect

We may collect the following categories of data:

• Identity Information: Name, email address, phone number, company affiliation, job title.
• Financial Information: For institutional clients, information relevant to regulatory due diligence (KYC/AML), including tax identification, banking details, and ownership structures.
• Technical Data: IP address, browser type, operating system, device information, and cookies.
• Usage Data: Pages visited, time spent, and interactions with our Website and Services.
• Communication Data: Records of correspondence, including emails, inquiries, and agreements.

3. How We Use Data

We use Personal Data for the following purposes:

• To provide, maintain, and improve our Services.
• To verify identity, conduct due diligence, and comply with KYC/AML regulations.
• To communicate with you regarding updates, transactions, and support.
• To comply with legal and regulatory obligations.
• To protect against fraud, unauthorized transactions, or misuse of our Services.
• For internal analytics, research, and business operations.

4. Legal Basis for Processing (GDPR)

We process Personal Data under one or more of the following legal bases:

• Consent: Where you have explicitly consented.
• Contract: Where processing is necessary for performance of a contract with you.
• Legal Obligation: Where processing is required by law (e.g., AML/KYC).
• Legitimate Interests: Where processing is necessary for our legitimate business operations, provided it does not override your rights.

5. Data Sharing & Disclosure

We may share your Personal Data with:

• Service Providers: Third parties who perform functions on our behalf (IT, cloud hosting, analytics, compliance).
• Regulators & Authorities: Where required by law, court order, or regulatory request.
• Business Transfers: In the event of a merger, acquisition, or sale of assets.
• Professional Advisors: Lawyers, auditors, consultants where necessary.

We do not sell Personal Data to third parties.

6. International Data Transfers

• Data may be transferred and processed outside your home jurisdiction, including the U.S., U.K., and E.U.
• Where applicable, we implement appropriate safeguards such as Standard Contractual Clauses (SCCs) and other recognized legal mechanisms.

7. Data Retention

We retain Personal Data for as long as necessary to fulfill the purposes for which it was collected, including compliance with regulatory, tax, and legal obligations.

8. Security

We implement appropriate technical and organizational measures to protect Personal Data from unauthorized access, loss, alteration, or disclosure. These include encryption, access controls, audit logging, and secure hosting environments.

9. Your Rights

Depending on your jurisdiction, you may have the following rights:

• Access: Obtain a copy of your Personal Data.
• Correction: Request correction of inaccurate data.
• Deletion: Request erasure of Personal Data ("right to be forgotten").
• Restriction: Request limitation of processing.
• Portability: Receive your Personal Data in a structured, machine-readable format.
• Opt-Out: Object to processing or marketing communications.

To exercise these rights, contact us at: privacy@gliesecap.com

10. Cookies

• We use cookies and tracking technologies for website functionality, analytics, and security.
• You can control cookies via your browser settings.

11. Children's Privacy

Our Services are not directed to individuals under 18, and we do not knowingly collect Personal Data from minors.

12. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be posted with a revised effective date. Continued use of our Services constitutes acceptance.

13. Contact

If you have questions about this Privacy Policy or how your data is handled, contact:

Gliese Capital LLC
Email: compliance@gliesecap.com