Hidden Road, Inc. and its affiliates (collectively “Hidden Road”), understand that your privacy is important to you and that you care about how your personal data is used. Hidden Road will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
The definition of Hidden Road includes, but is not limited to, the following affiliates and service receiving entities including, Hidden Road Partners CIV US LLC, Hidden Road Partners CIV US OTC LLC, Hidden Road Partners CIV UK Ltd, Hidden Road Partners UK LLP, Hidden Road Partners CIV NL B.V., Hidden Road Partners CIV (BVI) Ltd and Hidden Road Partners CIV SG PTE Ltd.
Please read this privacy notice carefully and ensure that you understand it.
This privacy notice applies to your use of Hidden Road’s onboarding portal, website or information provided by other means (“portal”). The portal may contain links to other websites. Please note that we have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy notices of any such websites before providing any data to them.
Personal data is as defined under the relevant Data Protection Legislation detailed below.
“Data Protection Legislation” is the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”), the onshored UK version of the GDPR (the “UK GDPR”), the Data Protection Act 2018, the Commodity Futures Trading Commission rules (17 C.F.R Part 160), US Securities and Exchange Commission Regulation SP, Singapore Personal Data Protection Act 2012 (the “PDPA”), the BVI Data Protection Act 2021 and other applicable data protection laws.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data and other online identifiers.
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.
It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau for Hidden Road Partners CIV UK Ltd. For all other Hidden Road entities, please contact us using the details in Part 12.
If you have any cause for complaint about Hidden Road Partners CIV UK Ltd’s use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 12.
Depending upon your use of the portal, we may collect and hold some or all of the personal and non-personal data, using the methods discussed below. We do not collect any personal data relating to children.
Data collected via the portal may include your name, company name and contact details for specific individuals in your organization, including phone number and email. It will also include information about your business such as corporate structure, portfolio samples, risk profile, revenue and historical returns, capital structure, compensation structure and other related matters to allow us to undertake appropriate due diligence.
Please note that any of the above does not apply to any information provided to us as part of our Responsible Disclosure of Information (or “whistleblowing”) policies and procedure.
In addition, technical information including IP address, browser type and version and operating system may be collected.
Under the Data Protection Legislation , we must always have a lawful basis for using personal data. The relevant lawful basis for our use of your data is generally that we need to process your data in order to perform under the contract you enter into with us. If you wish to know more about the basis for our processing of your personal data then please contact us using the details set out in section 12 below.. As noted above, we will use your personal data to undertake due diligence and assess your credit standing prior to offering and pricing services to you, based on your requests for products in the portal. We will also use your personal data and any updated personal data to undertake our KYC and AML obligations and facilitate ongoing monitoring of your account and the services we offer.
We will not use your personal data for marketing purposes. You will not be sent any unlawful marketing or spam.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 12.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
We will keep your personal data for as long as needed for its stated purpose or, where information is required to be retained by applicable regulation then it will be retained for such time as required by applicable regulation.
Personal data submitted to this portal is secured using data-at-rest and in-transit encryption. Data loss and intrusion prevention systems and advanced network monitoring tools are employed further securing this application environment. It should be noted, even with advanced security policies and platforms in place, there is always a risk of data loss.
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein) and/or the UK. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK or the EEA and under the Data Protection Legislation as follows:
We share your data within the group of companies of which we are a part or with other third parties appointed by us to perform processing of your data on our behalf. Where this involves the transfer of personal data outside the EEA or UK, our group and our third-party service providers ensure that personal data is protected. Within our group, this is ensured by requiring all companies within the group to follow the same rules with respect to personal data usage having entered into EU and UK-approved standard contractual clauses. Similarly, transfer of Singapore personal data to another country only according to the requirements prescribed under the regulations, to ensure that the standard of protection is comparable to the protection under the PDPA, unless exempted by the PDPC. We take all required steps to protect your personal data with respect to our third-party service providers . Where your data is being transferred to a third country not covered by a UK/EU by an adequacy decision then standard contractual clauses may be put in place as an appropriate safeguard.
Similarly, transfer of Singapore personal data within the group occurs only according to the requirements prescribed under the regulations, to ensure that the standard of protection is comparable to the protection under the PDPA, unless exempted by the PDPC.
Please contact us using the details below in Part 12 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
We will not share any of your personal data with any non-affiliated third parties for any purposes, other than those third parties that are providing services to us to support our product offering.
If we sell, transfer or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this privacy notice.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order or the instructions of a government authority.
In order to access the portal, you will be required to submit certain personal data. If you choose to withhold personal data that is required for the performance of our contract with you, then we may not be able to provide you with services.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request.”
All subject access requests should be made in writing and sent to the email shown in Part 12.
There is not normally any charge for a subject access request. If your request is “manifestly unfounded or excessive” (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days upon receipt of such request and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following email: dp*@hi********.com
You have the right to complain to a supervisory authority. Each EU Member State has a designated data protection supervisory authority.
You have the right to raise a complaint with the supervisory authority in the Member State where you live, where you work, or where any infringement took place.
If you are in the UK or doing business through Hidden Road Partners CIV UK Ltd then the relevant regulator is the Information Commission’s Office (“ICO”). The ICO’s contact details can be found here: https://ico.org.uk/global/contact-us/
If you are in The Netherlands or doing business through Hidden Road Partners CIV NL B.V. then the relevant regulator is the Dutch Data Protection Authority (“DPA” – in Dutch “Autoriteit Persoonsgegevens”). The DPA’s contact details can be found here: https://www.autoriteitpersoonsgegevens.nl/en/contact
If you are in Singapore, then the relevant regulator is the Personal Data Protection Commission Singapore (“PDPC”). The PDPC’s contact details can be found here: https://www.pdpc.gov.sg/
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on this portal and you will be deemed to have accepted the terms of the privacy notice on your first use of the portal following the alterations. We recommend that you check the portal regularly to keep up to date.
Where we regard proposed changes to be substantial or material, we will post proposed changes on this portal and will allow a period of at least 30 days for you to raise any objections before the change is made. However, in some cases, if you do not agree to such changes it may not be possible for us to continue to operate your account and/or provide certain products and services to you. Where relevant, we may further include details or information related to a particular service or activity at the point information is collected or the product or service is considered.
Last Updated: July 5, 2024
