Privacy Policy

1. Information We Collect

We may collect the following types of information:

1.1 Personal Information

Personal information is data that can be used to identify you as an individual. We may collect personal information such as:

• Name, email address, telephone number, and postal address
• Financial information necessary for investment transactions
• Professional information, such as occupation and job title
• Information provided when completing forms on our website
• Information provided when subscribing to our newsletter
• Information provided when contacting us or reporting issues with our website

1.2 Technical Information

When you visit our website, we may automatically collect technical information, including:

• IP address and browser type
• Operating system and device information
• Pages you view on our website
• How you arrived at our website (referrer data)
• Time and duration of your visit
• Actions you take on our website

2. How We Collect Your Information

We collect information through various methods:

• Direct interactions when you provide information by filling in forms, contacting us, or subscribing to our services
• Automated technologies or interactions, including cookies and similar technologies
• Third parties or publicly available sources, such as business partners, analytics providers, and search engines

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 To Provide Our Services

• Process investment inquiries and transactions
• Manage your relationship with us, including notifications about changes to our terms or privacy policy
• Provide information about investment opportunities that may interest you
• Respond to your questions and requests

3.2 To Improve Our Services

• Administer and protect our business and website
• Analyze website usage to improve user experience
• Develop new products and services
• Conduct research and analysis

3.3 Marketing

• Send relevant newsletters, updates, and marketing communications
• Measure the effectiveness of our marketing campaigns
• Deliver personalized content and recommendations

We will only send marketing communications if you have given your consent to receive such communications or if we are permitted to do so under applicable law. You can opt out of marketing communications at any time.

4. Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Consent: Where you have given clear consent for us to process your personal information for a specific purpose
• Contract: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract
• Legal obligation: Where processing is necessary for compliance with a legal or regulatory obligation
• Legitimate interests: Where processing is necessary for our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms

5. Cookies and Similar Technologies

Our website uses cookies and similar technologies to distinguish you from other users and collect information about your browsing habits. This helps us provide you with a good experience when browsing our website and allows us to improve our site.

We use the following types of cookies:

• Necessary cookies: Essential for the operation of our website
• Analytical/performance cookies: Allow us to recognize and count visitors and analyze website usage
• Functionality cookies: Used to recognize you when you return to our website
• Targeting cookies: Record your visit to our website, the pages you visit, and the links you follow

You can control and manage cookies in various ways. Please refer to our Cookie Policy for more information.

6. Data Sharing and Disclosure

We may share your personal information with the following parties:

6.1 Internal Third Parties

Other companies in the Timor Conti group acting as joint controllers or processors.

6.2 External Third Parties

• Service providers acting as processors who provide IT, system administration, and platform services
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers
• Regulators and other authorities who require reporting of processing activities in certain circumstances
• Business partners who provide services or products related to our business

6.3 Third-Party Marketing

We will not share your personal information with third parties for marketing purposes without your explicit consent.

6.4 Business Transfers

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. We will notify you if such a change of ownership or control occurs and outline any choices you may have regarding your information.

7. Data Security

We have implemented appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider:

• The amount, nature, and sensitivity of the personal data
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process the data
• Whether we can achieve those purposes through other means
• The applicable legal requirements

9. Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information, including the right to:

• Request access to your personal information
• Request correction of incomplete or inaccurate personal information
• Request erasure of your personal information
• Object to processing of your personal information
• Request restriction of processing your personal information
• Request transfer of your personal information
• Withdraw consent at any time where we rely on consent to process your personal information

If you wish to exercise any of these rights, please contact us using the details in the "Contact Us" section below.

10. International Transfers

We may transfer your personal information to countries outside the United Kingdom or European Economic Area (EEA). Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards, such as:

• Transferring to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or UK authorities
• Using specific contracts approved by the European Commission or UK authorities that give personal data the same protection it has in Europe and the UK
• Transferring data to organizations that are part of approved certification schemes

11. Children's Privacy

Our website and services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us, and we will delete such information from our systems.

12. Third-Party Links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

13. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new policy on this page and updating the "Last Updated" date.

We encourage you to review this policy periodically to stay informed about how we are protecting your information.

14. Contact Us

If you have any questions about this privacy policy or our privacy practices, please contact us at:

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.