Privacy policy

Privacy Policy

We at Capital Vaults Financial Technologies SPC and Bulk Asset Management Limited (collectively, “Bulk”, “We”, “Our”), respect your concerns about privacy. This privacy policy (the “Privacy Policy”) describes the types of personal information we obtain, how we use the information, with whom we share it and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. For the purposes of EU, and UK data protection laws, [Bulk Asset Management Limited] is a data controller of your personal information. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This Privacy Policy applies to the privacy practices of Bulk with respect to its processing of personal information online through the Website and mobile applications listed in Appendix A of this Privacy Policy (collectively, the “Sites”), as well as our offline privacy practices (unless they are specifically covered by a separate privacy policy).

Information We Obtain

We may obtain information about you in various ways, such as through our Sites, subscription documents and other documents and forms we receive from you or on your behalf.

We will collect and process the following data about you:

Information you give us. This is information about you that you give us by filling in forms on the Sites or by corresponding with us by phone, e-mail or otherwise. The information you give us may include:

  • Your name,
  • address,
  • e-mail address,
  • phone number,
  • financial and credit card information,
  • personal description and photographic images we collect from you,
  • information used to create your online account (such as username and password)
  • information about your transactions with us, our funds or our affiliates, and
  • other personal information you provide to us, such as through emails, subscription documents and other onboarding documents (that may include Social Security numbers, tax ID numbers or other government-issued identification numbers, to the extent permitted by applicable law), and other forms and documents you send us.

With regard to each of your visits to our Sites we will automatically collect the following information:

  • technical information, including the Internet Protocol (“IP”) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform,
  • information about your visit, including the full Uniform Resource Locators (“URL”), click stream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number,
  • information we receive from other sources. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) who may provide us information about you.

In addition to the information listed above, if you are a candidate to join the team and apply for a position with Bulk, we conduct a background check in connection with a team opportunity with Bulk, we may collect the following types of personal information to the extent permitted by applicable law:

  • national identification number or any other government-issued identification number,
  • date of birth,
  • gender,
  • employment and education history,
  • language proficiencies and other work-related skills,
  • citizenship and work authorization status,
  • ethnicity,
  • self-identified disability status,
  • results of criminal background checks,
  • information provided by references, and
  • other information about your qualifications for employment, such as information contained in your résumé or C.V. and compensation history and related information.

Providing personal information to us is voluntary on your part. If you choose not to provide us with certain information, we may not be able to offer you certain of our products and services, and you may not be able to access certain features of our Sites.

In connection with operating our business and marketing our products and services, to the extent permitted by applicable law, we may obtain personal information from consumer reporting agencies, our related entities, the responsible entities or administrators of managed investment schemes for which we provide services regulatory or government authorities, industry bodies, professional associations and other third parties.

Information We Obtain by Automated Means

When you visit our Sites, open our emails or interact with Bulk-related tools, widgets or plug- ins, we may obtain certain information by automated means, such as through cookies, web server logs, web beacons and JavaScript.

The information we obtain in this manner may include IP addresses, unique device identifiers, browser and operating system characteristics, device characteristics, language preferences, clickstream data, referring/exit URLs, information on actions taken, dates and times of activity and other technical information. These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with our products, services and Sites; (3) tailor our products, services and Sites around your preferences; (4) measure the usability of our products, services and Sites and the effectiveness of our communications; and (5) otherwise manage and enhance our products, services and Sites.

Information about our cookie practices in the European Union is available in our https://capitalvaultsllc.com/en/cookiepolicy To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.

Online Tracking and Interest-Based Advertising

When you use the Sites, we may collect personal information about your online activities, over time and across third-party websites, to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent to the processing of your personal information for direct marketing purposes.

You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection takes place both on the Sites and on third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

How We Use the Information We Obtain

We use information held about you in the following ways:

Information you give to us

We will use this information:

  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us,
  • to comply with applicable laws and legislation,
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about,
  • to notify you about changes to our service,
  • create, manage and administer accounts you hold with us or with one of our funds,
  • verify your identity and conduct identity and background checks for anti-money laundering purposes where you or your related organization are applying for our products or services,
  • manage career opportunities, including for recruitment purposes (such as processing job applications and conducting background checks in accordance with applicable law), employee onboarding and other human resources purposes,
  • to ensure that content from our site is presented in the most effective manner for you and for your device.
Information we collect about you

We will use this information:

  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes,
  • to comply with applicable laws and legislation,
  • to improve our site to ensure that content is presented in the most effective manner for you and for your device,
  • to allow you to participate in interactive features of our service, when you choose to do so,
  • as part of our efforts to keep our site safe and secure,
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you,
  • auditing, billing and reconciliation activities and other internal functions),
  • protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities
  • to make suggestions and recommendations to you and other users of our site about, goods or services that may interest you or them Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

As a general matter, we use the personal information we obtain to comply with applicable legal requirements, carry out our contractual obligations and pursue our legitimate interests (such as managing our Sites and client relationships). Where required by applicable law, we obtain consent to process personal information. We also may use the personal information we obtain in other ways for which we provide specific notice at the time of collection.

Disclosure of your Information

We do not sell or otherwise share personal information about you, except as described in this Privacy Policy. We share your personal information with members of our group for the purposes identified in this Privacy Policy. Members of our group includes Bulk and its employees, officers, directors, contractors, consultants, service providers, parent companies, subsidiaries, and affiliates (“Capital Vaults Team”). We do not authorise any service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include fund administrators and entities that provide web hosting, analytics and other IT services. In addition, we may share your personal information with your authorized representatives.

Personal information shall be disclosed, to the extent necessary, if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use of the Website and other agreements; or to protect the rights, property, or safety of the Capital Vaults Team, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

The Bulk Team also may disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other government entities based on a lawful disclosure request; (3) to establish, exercise or defend the legal rights (including the property and safety) of the Bulk Team; (4) when we believe disclosure is necessary or appropriate to prevent harm or financial loss; (5) in connection with an investigation of suspected or actual fraudulent or illegal activity; (6) exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction or (7) otherwise with your consent. We reserve the right to transfer personal information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, spin-off, dissolution or liquidation).

Data Transfers

When you provide personal information to Bulk you are providing it to an entity which is not located in the European Economic Area (“EEA“). We may transfer the personal information we obtain about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. To the extent required by applicable law, when we transfer your information to recipients in other countries (such as but not limited to the United States of America, British Virgin Islands, Republic of South Africa, or Cayman Islands), we will protect that information as described in this Privacy Policy.

If you are located in the EEA, we will comply with applicable legal requirements regarding the provision of appropriate safeguards for the transfer of personal information to recipients in countries for which the European Commission has not issued an adequacy decision. If you are located in the UK, we will comply with applicable legal requirements regarding the provision of appropriate safeguards for the transfer of personal information to recipients in countries for which the Information Commissioner’s Office has not issued an adequacy decision. These safeguards may include data transfer agreements, copies of which may be obtained by contacting us as indicated in the How to Contact Us section of this Privacy Policy.

Your Rights and Choices

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, ask us to remove your information from our mailing lists or to submit a request regarding your personal information, please contact us as indicated in the How To Contact Us section of this Privacy Policy. You also can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.

In certain circumstances and to the extent permitted by law, you may have the following rights in relation to the processing of your personal information:

  • Access. To request a copy of the personal information we process in relation to you and to be informed about how we use and share your personal information.
  • Object. To object to the processing of your personal information if (i) we are processing your personal information on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if we are processing your personal information for direct marketing purposes.
  • Correction. To request that we update the personal information we process in relation to you, or to correct personal information that you think is incorrect or incomplete.
  • Erasure. To ask that we delete personal information that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.
  • Restriction. To request that we restrict the way in which we process your personal information, for example, if you dispute the accuracy of your personal information or have raised an objection which is under consideration.
  • Portability. To request a copy of your personal information that you have provided to us in a commonly used electronic format such as through the completion of an application form.
  • Automated decision making. To request manual intervention if you are subject to automated decisions where the decision results in a legal or similar significant effect to you.

Depending on your location, you may have the right to file a complaint with a data protection authority if you are not satisfied with our response. Where provided by law, you may withdraw any consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward.

We may need to request specific information from you to help us confirm your identity and ensure your right to access to the personal information requested, or to exercise any of your other rights. This is to ensure that personal information 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 personal information processed in relation to you, including, for example, the nature and location of your relationship with us. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

Links to Third-Party Websites, Apps and Other Features

Our Sites may provide links to other websites, apps and features. The providers of the websites, apps and features may use automated means to collect information regarding your use of the Sites and your interactions with the other websites, apps and features. These websites, apps and features may operate independently from us and may have their own privacy policies, which we strongly advise you review. To the extent that any website, app or feature is not owned or controlled by us, we are not responsible for the content, any use of the website, app or feature, or the privacy practices (including cookie practices) of the website, app or feature.

How We Protect Personal Information

We maintain administrative, technical, organisational and physical safeguards which are designed to protect the personal information we obtain against unauthorized or unlawful use, disclosure, access, loss, destruction or damage.

When considering the safeguards which Capital Vaults utilises a risk-based approach considering the following factors is undertaken:

  • the state of the art of commercial available technology;
  • the cost of implementation;
  • the nature, scope, context and purpose of processing; and
  • the severity and likelihood of the risks.

The safeguards we employ include, where appropriate, pseudonymisation and encryption, the maintenance of plans and procedures to restore access and availability to personal information in a timely manner in the event of a physical or technical incident which restricts or inhibits access to personal information. Where we engage with processors, we choose those that provide sufficient guarantees about their data security measures.

We maintain a process for regularly testing, assessing and evaluating the effectiveness of these safeguards.

Retention of Personal Information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Such information may be retained after our client relationship has ceased, and for client identification purposes in accordance with our data retention procedures. You may ask us for further information on these.

To determine the appropriate retention period for personal data, we consider the amount, nature, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law, we may have to keep basic information about our customers (including contact, identity) for a period of time after they cease being customers for regulatory and/or tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Such personal data, once anonymised, cannot be used to identify you.

Children’s Personal Information

We do not knowingly collect or solicit personally identifiable information from children under 18; if you are a child under 18, please do not attempt to register for out services or send any personal information about yourself to us. If we learn we have collected personal information from a child under 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us personal information, please contact us at info@capitalvaultsllc.com or see How to Contact Us, below.

Updates To Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our privacy practices. We will indicate in this Privacy Policy when it was most recently updated.

How to Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please email us at info@capitalvaultsllc.com.

EEA:

Residents of the EEA may contact us at: dataprotection@fivewest.ie

UK:

Residents of the UK may contact us at: dataprotection@fivewest.ie


Appendix A

This Privacy Policy applies to Bulk online processing of personal information through the following websites and mobile apps:

www.capitalvaultsllc.com

Capital Vaults Platform (in browser application)

Capital Vaults Platform (mobile application)


Last updated: 12 February 2022