FundEmpire Holdings ("FundEmpire", "we", "us", or "our") operates an invitation-only digital ecosystem connecting institutional capital partners, project owners, and strategic allocators. This Privacy Policy describes how we collect, use, disclose, retain, and safeguard information in connection with our platform and related services (collectively, the "Services"). By accessing the Services, you acknowledge the practices described below.
1. Information We Collect
We collect information that you submit directly to us, information generated through your use of the Services, and information obtained from third parties for verification, anti-money laundering ("AML"), counter-terrorism financing ("CTF"), sanctions screening, and know-your-customer ("KYC") purposes. This may include identity information, professional credentials, beneficial ownership disclosures, source-of-funds documentation, mandate parameters, and technical metadata such as IP address and device identifiers.
2. Purposes of Processing
Personal and institutional information is processed for: (a) eligibility assessment and member onboarding; (b) compliance with applicable AML, CTF, sanctions, tax-reporting, and securities regulations; (c) operation, maintenance, and security of the Services; (d) facilitation of mandates and introductions; (e) enforcement of our Terms of Service and Code of Conduct; and (f) protection of the legitimate interests of FundEmpire, its members, and counterparties.
3. Lawful Bases
We rely on the following lawful bases, as applicable: performance of a contract, compliance with a legal obligation, our legitimate interests in operating a secure and reputable network, and, where required, your explicit consent. Consent may be withdrawn at any time without affecting prior lawful processing.
4. Disclosure of Information
Information may be disclosed to: (a) other vetted members strictly in furtherance of a mandate you have authorized; (b) regulators, law enforcement, tax authorities, and judicial bodies where legally required; (c) professional advisors, auditors, and service providers bound by confidentiality obligations; and (d) successors in connection with a merger, acquisition, or restructuring of FundEmpire. We do not sell personal information.
5. International Transfers
Given the cross-border nature of institutional capital, your information may be transferred to, stored in, and processed in jurisdictions other than your own. Where required, we implement appropriate safeguards such as Standard Contractual Clauses or equivalent transfer mechanisms.
6. Data Retention
We retain records for the duration of your membership and for such additional period as is required to satisfy regulatory, accounting, tax, audit, and legal obligations, typically a minimum of seven (7) years from the date of last transaction, or longer where mandated by competent authorities.
7. Security
We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, alteration, disclosure, or destruction, including encryption in transit and at rest, access controls based on least-privilege principles, and continuous monitoring. No system, however, can guarantee absolute security.
8. Your Rights
Subject to applicable law and to verification of your identity, you may request access to, rectification of, restriction of processing of, portability of, or deletion of your personal information. Such rights may be limited where necessary to comply with statutory retention obligations or to safeguard the rights of other parties.
9. Confidentiality of Mandates
All mandate information, deal terms, counterparty identities, and related communications exchanged through the Services are deemed strictly confidential and are subject to the binding non-disclosure obligations set forth in our Terms of Service and Code of Conduct.
10. Changes to this Policy
We may amend this Privacy Policy from time to time to reflect legal, regulatory, or operational developments. Material changes will be communicated to members through the Services or by other reasonable means. Continued use of the Services constitutes acceptance of the revised Policy.
11. Contact
For privacy-related enquiries, including the exercise of statutory rights, please contact the FundEmpire Data Protection Office at support@fundempire.co or write to us at 1 Cranmer St. Nottingham, United Kingdom.