Chronos Capital LLC understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who uses the website, products, and tools within capguru.io (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
We comply with the EU-U.S. Privacy Shield Framework, as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles that are a part of the Privacy Shield program (the “Principles”). If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view our certification, please visit http://www.privacyshield.gov/.
Please read this Privacy Policy (“Policy”) carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“personal data” for the purposes of the EU-US Privacy Shield means any and all data that relates to an identified or identifiable natural person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site or other means of transfer. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Chronos Capital LLC, a company registered in Delaware, USA under company number 6752304 whose registered address is 244 Fifth Avenue, New York, NY 10001
A “natural person” is a living human being. The law sometimes treats corporations and other business entities as “persons,”, so using the term “natural person” makes it clear that we’re talking about a human being.
A “data subject” is the identified or identifiable natural person to which the personal data relates.
“Sensitive information” under the EU-U.S. Privacy Shield means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or health or sex life.
“Processing” of personal data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
A “controller” of personal data is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
A “processor” of personal data is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
2. Information About Us
2.1 Our Site is owned and operated by Chronos Capital LLC, a company registered in Delaware, USA under company number 6752304 whose registered address is 244 Fifth Avenue, New York, NY 10001
2.3 Our Data Protection Officer is can be contacted by email at admin@capguru.io.
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site 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 policies of any such websites before providing any data to them.
This Privacy Shield Privacy Policy covers personal data about data subjects who are citizens of any EEA member state or of the United Kingdom, where the personal data is transferred to, and/or processed in, the United States.
If a data subject gives his or her consent to the export of his/her personal data to the United States, and/or processing of his or her personal data in the United States, that consent governs such export and processing and this Policy doesn’t apply to any export or processing within the scope of that consent. To the extent that the data subject’s consent does not apply, this Policy will apply.
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with your local supervisory authority in the EU.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. Data: Purpose for processing personal data, types of personal data processed & third parties to which personal information is disclosed
i) Types of Personal Data collected
We collect maintain, use, and share “Business Personal Data” and “Human Resources Personal Data”. Here is what we mean by these terms:
“Business Personal Data” is personal data that enables identification of, authentication of, coordination of, and/or communication to, from, between, and/or among people who work for or with us, and/or for whom we provide goods or services. These people include but aren’t limed to, employees, agents, contractors, customers, suppliers, users of our goods and services and others with or through whom we do business or might do business, or for whose benefit we do business. Business Personal Data includes, but is not limited to, contact information, identification information, information about whereabouts, information about travel plans, information about goods and/or services to be provided by (or to) us, applications used, manner and extent of the use of applications, and directory information such as name, mobile and/or land telephone number, fax number, e-mail address, physical address, user ID, IP address, picture, language(s) spoken, title, organizational role, and systems or processes that such persons are authorized to utilize.
“Human Resource Personal Data” is human resources and benefits information used by Chronos Capital LLC to evaluate, employ, retain, administer the employment and/or contractor relationship with, and/or receive or provide the services of, employees and/or direct or indirect contractors who are being considered to do, who do, or have done work for, or for the benefit of, Chronos Capital LLC.
Also – where we say that we “anonymize” personal data, that means that we combine it with other information, redact it, or otherwise make it so that it no longer reasonably identifies the data subject.
We collect Business Personal Data and Human Resources Personal data, defined above.
ii) Purposes for which Personal Data collected
We collect personal data for the following reasons:
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- So that data subjects can be contacted, and/or can contact each other, in order to do business.
- So that we can provide goods or services to data subjects and/or their organizations and/or receive goods or services from data subjects and/or their organizations.
- So that we can monitor the use of our goods and services for the purposes of maintenance, improvement, and license compliance.
- So that we can give to employees, agents, and/or contractors access to the systems and databases that they need to perform their work.
- So that we can effectively manage human resources, provide opportunities for individuals, and generally make advice and analyses available regarding employer-employee and contractor relationships between us and prospective, current, and past employees and/or contractors.
iii) Type or identity or third parties to which we disclose personal information and the purposes for which we do so
(a) Anonymized information. If we anonymize personal data, we may share that personal data with anyone for any purpose.
(b) Persons with whom we do business. We may provide personal data to others involved in the provision or receipt of goods and/or services so that we can cooperate in providing or receiving goods and/or services.
(c) Outsourcing providers. We may provide personal data to outsourcing providers who perform functions in support of our conduct of business. This might include data processing, storage, system administration, and similar functions.
(d) Successors. If we sell or otherwise transfer all or a part of our business, or are investigating the possibility of doing so, we may transfer to, or share with, the actual or potential buyer or other transferee, the personal data associated with the actual or potentially sold or transferred business.
(e) To comply with legal requirements. We may share your information if required by law enforcement, government agencies, courts, or others where we believe that our cooperation with information requests is required by law.
We provide personal information to others so that we can accomplish the purposes stated above.
iv) Additional Details
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data:
5.1 name;
5.2 date of birth;
5.3 gender;
5.4 business/company name
5.5 job title;
5.6 profession;
5.7 contact information such as email addresses and telephone numbers;
5.8 demographic information such as postcode, preferences, and interests;
5.9 financial information such as credit/debit card numbers;
5.10 IP address;
5.11 web browser type and version;
5.12 operating system;
5.13 URLs starting with a referring site, your activity on Our Site, and the site you exit to;
5.14 Financial and legal data concerning ownership rights, vesting periods, capitalisation tables;
5.15 Financial and legal instrument data concerning company rights; employee ownership; accounting information; business plans; future growth projections;
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you because you have consented to Our use of your personal data (e.g., by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Supplying Our products AND/OR services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.2 Personalising and tailoring Our products AND/OR services for you;
6.2.3 Replying to emails from you;
6.2.4 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by telling us via the unsubscribe links provided;
6.2.5 Market research;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 Personal data will be retained as long as you wish to be considered for our products and services, if at any time you do not wish to participate please inform us in writing at the address listed on the website.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EU and under the GDPR including:
7.2.1 We will only store data on recognised market-leading cloud data providers and computers, with AES security, password access, and access right controls.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 We will only store data on recognised market-leading cloud data providers who have the necessary GDPR compliance requirements and local computers, with AES security, password access, and access right controls.
8. Do We Share Your Data?
8.1 We may share your data with other companies in Our group. This includes Our subsidiaries AND/OR Our holding company and its subsidiaries.
8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EU under the GDPR
8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4 when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
10.2 In the UK: you may also wish to sign up for one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.
11. Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in section 13.
13. Independent Recourse Mechanism for EU Individuals
In compliance with the Privacy Shield Principles, Chronos Capital LLC commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Chronos Capital LLC at: admin@capguru.io
Chronos Capital LLC has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. In the event we are unable to resolve your concern, Persona commits to cooperate with the relevant EU Data Protection Authority and Information Commissioner and comply with their advice regarding personal and human resource data transfers and the Privacy Shield Principles. Per the terms of the frameworks and under certain circumstances, you may invoke binding arbitration.
In the event we are unable to resolve your concern, Chronos Capital LLC commits to cooperate with the relevant EU Data Protection Authority and Information Commissioner and comply with their advice regarding personal and human resource data transfers and the Privacy Shield Principles. Per the terms of the frameworks and under certain circumstances, you may invoke binding arbitration.
14. Privacy Policy – Additional Matters
a) FTC oversight
Chronos Capital LLC is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
b) Ability to invoke binding arbitration
The Principles require that organizations are obligated to arbitrate claims and follow the terms as set forth in Annex I, provided that an individual has invoked binding arbitration by delivering notice to the organization at issue and following the procedures and subject to conditions set forth in Annex I
You may, under certain circumstances, be able to invoke binding arbitration.
“Annex I” contains the terms under which Privacy Shield certifying organizations are obliged to arbitrate claims as required by the Recourse, Enforcement, and Liability Principles. Where an individual has invoked binding arbitration by delivering the required notice, we will arbitrate as required by the terms in Annex I. You can Annex I for yourself. The EU-U.S. Privacy version begins at https://privacyshield.gov/article?id=ANNEX-I-introduction
c) Disclosure of Personal Information in response to lawful requests by public authorities
We will disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
15. How to Contact Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at admin@capguru.io. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).
16. Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
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