Privacy Policy

1. Introduction

Syndicated Investment LTD ("we," "us," "our," or "Syndicated") is committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, share, and protect your personal information in accordance with the General Data Protection Regulation (GDPR), the UK Data Protection Act 2018, and other applicable data protection laws.

Company Details:

Company Name: Syndicated Investment LTD
Registered Office: 20 Wenlock Road, London, N1 7GUUnited Kingdom
Authorization: Authorized and regulated by Progression Financial Services
Contact Email: privacy@syndicated.ch
Data Protection Officer: dpo@syndicated.ch

2. Data Controller

Syndicated Investment LTD is the data controller responsible for your personal data. If you have any questions about this Privacy Policy or how we handle your data, please contact us using the details provided above.

3. Personal Data We Collect

We collect and process various types of personal data depending on your relationship with us:

3.1 For Prospective and Current Investors:

Identity Information: Full name, date of birth, nationality, government-issued ID numbers
Contact Information: Email address, phone number, postal address
Financial Information: Bank account details, investment portfolio information, source of funds, net worth, income details, tax identification numbers
Professional Information: Employment status, occupation, business affiliations
Investment Preferences: Risk tolerance, investment objectives, investment experience
Due Diligence Information: Proof of identity, proof of address, beneficial ownership information
Transaction Data: Investment history, transaction records, payment information

3.2 For Website Visitors:

Technical Data: IP address, browser type, device information, operating system
Usage Data: Pages visited, time spent on pages, click patterns, referring URLs
Cookie Data: Information collected through cookies and similar technologies (see Section 11)

3.3 For Business Contacts and Partners:

Professional Information: Name, job title, company, business contact details
Communication Records: Correspondence, meeting notes, call records

4. How We Collect Personal Data

We collect personal data through the following methods:

Directly from you: When you complete application forms, register for our services, communicate with us, or attend our events
Automated technologies: Through cookies and similar tracking technologies when you use our website
Third parties: From credit reference agencies, anti-money laundering databases, public registers, business partners, and regulatory bodies
Publicly available sources: Professional networks, company registries, and public records

5. Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR:

5.1 Contractual Necessity (Article 6(1)(b) GDPR)

Processing necessary to enter into or perform a contract with you, including:

Processing investment applications
Managing your investment portfolio
Executing transactions
Providing investor services

5.2 Legal Obligation (Article 6(1)(c) GDPR)

Processing required to comply with legal obligations, including:

Anti-money laundering (AML) and counter-terrorist financing (CTF) checks
Know Your Customer (KYC) procedures
Tax reporting obligations (e.g., FATCA, CRS)
Regulatory reporting to the Financial Conduct Authority (FCA) and other regulators
Record-keeping requirements

5.3 Legitimate Interests (Article 6(1)(f) GDPR)

Processing necessary for our legitimate business interests, including:

Fraud prevention and security
Business development and marketing
Improving our services
Network and information security
Internal administration

5.4 Consent (Article 6(1)(a) GDPR)

Where required by law or when we ask for your explicit consent, such as:

Marketing communications
Certain cookies and tracking technologies
Processing sensitive personal data where not otherwise permitted

6. How We Use Your Personal Data

We use your personal data for the following purposes:

6.1 Investment Services:

Assessing your suitability as an investor
Processing investment applications and transactions
Managing your investment portfolio
Providing investor reporting and communications
Executing redemptions and distributions

6.2 Compliance and Legal Obligations:

Conducting KYC and due diligence checks
Performing AML and CTF screening
Meeting regulatory reporting requirements
Maintaining records as required by law
Responding to legal processes and regulatory requests

6.3 Business Operations:

Communicating with you about our services
Providing customer support
Improving our website and services
Conducting market research and analysis
Managing business relationships

6.4 Marketing (with consent):

Sending information about new investment opportunities
Sharing insights and market updates
Inviting you to events and webinars

6.5 Security and Fraud Prevention:

Detecting and preventing fraud
Protecting against security threats
Ensuring the integrity of our systems

7. Data Sharing and Disclosure

We may share your personal data with the following categories of recipients:

7.1 Service Providers:

Banking and payment processors
IT and cloud service providers
Data analytics providers
Professional advisors (lawyers, accountants, auditors)
Marketing and communication service providers

7.2 Regulatory and Legal Bodies:

Financial Conduct Authority (FCA)
Progression Financial Services
Tax authorities (HMRC, IRS, and others)
Law enforcement agencies
Courts and dispute resolution bodies

7.3 Business Partners:

Co-investment partners
Fund administrators
Custodians and trustees
Investment targets and portfolio companies (where relevant)

7.4 Corporate Transactions:

Potential buyers or investors in the event of a sale, merger, or acquisition
Professional advisors in connection with corporate transactions

7.5 Third-Party Due Diligence:

Credit reference agencies
Identity verification services
AML/CTF screening providers
Background check providers

Important: We only share your data when necessary and ensure all recipients are bound by confidentiality obligations and comply with data protection laws. We do not sell your personal data to third parties.

8. International Data Transfers

As we operate internationally and use service providers located in different countries, your personal data may be transferred to and processed in countries outside the European Economic Area (EEA) and Switzerland, including the United States.

When we transfer your data internationally, we ensure appropriate safeguards are in place:

Adequacy Decisions: Transfers to countries deemed adequate by the European Commission
Standard Contractual Clauses (SCCs): EU-approved contract terms ensuring data protection
Binding Corporate Rules: Internal policies for international group companies
Explicit Consent: Where you have given explicit consent for the transfer

You have the right to obtain information about the safeguards we use for international transfers by contacting us.

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations.

Retention Periods:

Investment Records: Typically 7-10 years after the end of the investment relationship, or longer if required by law
AML/KYC Documentation: Minimum 5 years from the end of the business relationship (may be longer under specific regulations)
Tax Records: As required by applicable tax laws (typically 6-10 years)
Marketing Data: Until you withdraw consent or 3 years after last interaction
Website Analytics: Typically 26 months
CCTV Footage (if applicable): 30 days unless required for legal purposes

After the retention period expires, we securely delete or anonymize your personal data.

10. Your Data Protection Rights

Under GDPR and applicable data protection laws, you have the following rights:

10.1 Right of Access (Article 15 GDPR)

You can request a copy of the personal data we hold about you and information about how we process it.

10.2 Right to Rectification (Article 16 GDPR)

You can request correction of inaccurate or incomplete personal data.

10.3 Right to Erasure/"Right to be Forgotten" (Article 17 GDPR)

You can request deletion of your personal data in certain circumstances, such as:

The data is no longer necessary for the purposes collected
You withdraw consent (where processing is based on consent)
You object to processing and there are no overriding legitimate grounds
The data has been unlawfully processed

Note: This right is not absolute and may not apply if we have legal obligations to retain the data.

10.4 Right to Restriction of Processing (Article 18 GDPR)

You can request that we limit how we use your personal data in certain circumstances.

10.5 Right to Data Portability (Article 20 GDPR)

You can request a copy of your personal data in a structured, commonly used, machine-readable format and have it transferred to another controller.

10.6 Right to Object (Article 21 GDPR)

You can object to:

Processing based on legitimate interests
Direct marketing (including profiling for marketing purposes)
Processing for scientific, historical research, or statistical purposes

10.7 Rights Related to Automated Decision-Making (Article 22 GDPR)

You have the right not to be subject to decisions based solely on automated processing that produces legal or significant effects.

10.8 Right to Withdraw Consent

Where processing is based on consent, you can withdraw your consent at any time.

10.9 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority:

UK: Information Commissioner's Office (ICO) - https://ico.org.uk
Switzerland: Federal Data Protection and Information Commissioner (FDPIC)

To exercise your rights, contact us at: privacy@syndicated.ch

We will respond to your request within one month, though this may be extended by two additional months in complex cases.

11. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your experience and analyze website usage.

Types of Cookies We Use:

Essential Cookies: Required for website functionality (e.g., security, session management)

Analytics Cookies: Help us understand how visitors use our website (e.g., Google Analytics)

Functional Cookies: Enable enhanced functionality and personalization

Marketing Cookies: Used to deliver relevant advertisements and track campaign effectiveness

Cookie Management:

You can control cookies through your browser settings. However, disabling certain cookies may affect website functionality.

For more information, see our Cookie Policy or contact us.

12. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

Encryption: Data encryption in transit (TLS/SSL) and at rest
Access Controls: Role-based access with multi-factor authentication
Regular Security Audits: Penetration testing and vulnerability assessments
Employee Training: Regular data protection and security training
Secure Infrastructure: ISO 27001 compliant data centers
Incident Response: Procedures for detecting and responding to data breaches
Vendor Management: Due diligence on third-party service providers

While we strive to protect your data, no internet transmission is completely secure. We cannot guarantee absolute security.

13. Data Breach Notification

In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, we will:

Notify the relevant supervisory authority within 72 hours of becoming aware of the breach
Notify affected individuals without undue delay if the breach poses a high risk
Document all breaches and our response measures

14. Children's Privacy

Our services are not directed at children under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a child, we will delete it promptly.

15. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of significant changes by:

Posting the updated policy on our website with a new "Last Updated" date
Sending an email notification to registered users (where appropriate)
Obtaining fresh consent where required by law

We encourage you to review this policy regularly.

17. Marketing Communications

How We Use Your Data for Marketing:

With your consent, we may send you information about:

New investment opportunities
Market insights and research
Company news and updates
Events and webinars

Your Marketing Preferences:

You can opt out of marketing communications at any time by:

Clicking the "unsubscribe" link in any marketing email
Contacting us at [privacy@syndicated.ch]
Updating your preferences in your account settings

Note: Even if you opt out of marketing, we will still send you essential service-related communications.

18. Automated Decision-Making and Profiling

We may use automated processing for:

Initial investor suitability assessments
Fraud detection and prevention
Risk scoring

You have the right to request human intervention, express your point of view, and contest automated decisions. Contact us if you have concerns about automated processing.

19. Special Categories of Personal Data

We generally do not collect "special categories" of personal data (e.g., health data, biometric data, political opinions) unless:

Required for legal compliance (e.g., disability accommodations)
You provide explicit consent
Necessary for legal claims

When we do process such data, we implement additional safeguards.

20. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

Data Protection Officer Syndicated Investment LTD, 20 Wenlock Road, London, N1 7GU United Kingdom

Email: privacy@syndicated.ch / dpo@syndicated.ch Phone: +82 123 456 6731

Supervisory Authority Contact: Information Commissioner's Office (ICO)Website: https://ico.org.uk Helpline: 0303 123 1113

Appendix: Definitions

Personal Data: Any information relating to an identified or identifiable natural person.

Processing: Any operation performed on personal data, including collection, storage, use, disclosure, and deletion.

Data Controller: The entity that determines the purposes and means of processing personal data.

Data Processor: An entity that processes personal data on behalf of the data controller.

GDPR: General Data Protection Regulation (EU) 2016/679.

EEA: European Economic Area, comprising EU member states plus Iceland, Liechtenstein, and Norway.

This Privacy Policy is provided in English. If translated, the English version shall prevail in case of any discrepancies.

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