1.    Data Collection Overview

a. Direct User-Provided Data

Currently, our website does not support direct user data submission. Nonetheless, you might provide us with personal details for accessing specific services, offering services to us, or for information requests. This could include your name, contact details, resume, payment information, and other personal specifics.

Unless mandated by regulations like the Office of Foreign Assets Control (OFAC) and similar laws, there's no legal or contractual necessity for you to supply us or our partners with your personal data. However, the absence of such data might limit our ability to offer specific services or information. For instance, employment applications or contracts with potential investors require certain personal details.

b. Data Acquired from External Sources

We gather data from various external sources, such as resumes from recruitment agencies, medical fitness reports, background checks, social media insights, and publicly available restricted trade lists. This also includes data from business partners and vendors to facilitate our investment services. While this data is often aggregated and non-identifiable, it may sometimes include personal details.

c. Automatically Collected Data

i. Device and Usage Information

We automatically collect data about the devices you use to access our website. This includes IP addresses, location data, device identifiers, browser types, operating system, and more. We analyze how you interact with our website, including page views, click patterns, and usage statistics.

ii. Cookies and Other Digital Tools

Our site uses server logs, cookies, and tracking pixels to gather data about your usage. Cookies help us recognize your device, store preferences, understand your site navigation, tailor content and ads to your interests, perform analytics, and maintain site security. You can manage cookie settings in your browser.

d. Online Analytics

We employ third-party analytics services like Google Analytics to process the data mentioned above. These services collect data, including your IP address, to evaluate your website usage. You can opt out of Google Analytics data collection.

e. Do-Not-Track Signals

We currently do not respond to browser DNT signals. Third-party analytics providers may collect data on our site, subject to their privacy policies.

2.    Utilization of Collected Information

We use the collected data for various purposes, including to provide and improve our services, respond to requests, conduct market research, internal reporting, recruitment, legal compliance, and site administration. We may combine your data with information from affiliates, vendors, and third parties.

Aggregated or anonymized data may be used for research and marketing and shared with third parties.

3.    Disclosure of Information

We may share your data with third parties under certain conditions, such as with your consent, to service providers, for legal compliance, in business transfers, or to protect our rights and safety.

4.    Legal Basis for Data Processing

Our processing of personal data is based on legitimate business interests, legal compliance, contractual obligations, and, in some cases, your consent.

5.    User Rights and Choices

You have rights to access, modify, or delete your personal data. California residents have specific rights under the CCPA, including requests for data access, deletion, and information about data sales.

6.    California Resident Notice

California law requires additional disclosures about personal data collection, use, and sharing, as detailed in this policy.

7.    Data Transfer

Personal data is processed in the United States, which may have different privacy laws than your jurisdiction.

8.    Children's Privacy

Our site is not intended for children under 16. We take steps to delete any inadvertently collected data from children.

9.    Security Measures

We implement various security measures to protect your data, although no system is entirely secure.

10. Data Retention

       We retain your data as necessary for our business purposes and legal requirements.

11. Third-Party Links and Services

       Our site may link to third-party sites and services, for which we are not responsible.

12. Policy Updates

       We may update this policy periodically. Significant changes will be communicated as required by law.

13. Contact Information

       For any inquiries about this policy, please contact us at Inquiries@thinkapf.com