Privacy Policy

Fundface Ltd and its subsidiaries (“Fundface Hedge Fund”) respect and protect the privacy of the visitors to Fundface’s website and Fundface’s clients who use Fundface’s  Services. To ensure transparency, this Privacy Policy describes Fundface’s (and its subsidiaries) information handling practices when you access content of Fundface’s website located at fundface.org (http://www. fundface.org/), and when you are a client of Fundface or its subsidiaries.

Acceptance of the privacy policy

By accessing and using Fundface’s Services, you signify that you have reviewed the terms of this Privacy Policy. Where Fundface requires your consent to process your personal information, Fundface will ask for your consent to the collection, use, and disclosure of your personal information as described further below. Fundface may provide additional “just-in-time” disclosures or additional information about the data collection, use, and sharing practices of specific Services. These notices may supplement or clarify Fundface’s  privacy practices, or may provide you with additional choices about how Fundface processes your data.
 If you do not agree with, or you are not comfortable with, any aspect of this Privacy Policy, you should immediately discontinue access or use of Fundface’s  Services. 

Changes to this privacy policy

Fundface reserves the right to modify this Privacy Policy at any time, and when required by law, Fundface will notify you of changes to this Privacy Policy. If Fundface makes any`        a material changes, Fundface will notify you by email (sent to the email address specified in our database), or by means of a notice on Fundface’s  Services prior to the change becoming effective.

Personal information collected by Fundface

Personal information is data that can be used to identify you directly or indirectly, or to contact you. Fundface’s  Privacy Policy covers all personal information that you voluntarily submit to Fundface and that Fundface obtains from Fundface’s  partners. This Privacy Policy does not apply to anonymised data, as it cannot be used to identify you.
 You may be asked to provide personal information at any time that you are in contact with any of the Fundface companies. The Fundface companies may share your personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve Fundface’s products, services, and content (see the section below).
 Except as described in this Privacy Policy, Fundface will not give, sell, rent, or loan any personal information to any third party. 

Personal information collected

Fundface collects personal information to provide you with Fundface’s  Services. When Fundface requires specific personal information from users, it is because such information is relevant for certain purposes. Any information you provide to Fundface that is not required is voluntary.
 For example, Fundface collects personal information when you use or request information about Fundface’s Services, subscribe to marketing communications, request support, complete surveys, or sign up for a Fundface event or webinar. Fundface may also collect personal information from you offline, such as when you attend one of Fundface’s events, or when you contact your relationship manager. Fundface may use this information in combination with other information Fundface collects about you.
 You are free to choose whether to provide Fundface with the types of personal information described below, but Fundface may not be able to serve you as effectively, or offer you some or all of Fundface’s  Services, when you choose not to share certain information with Fundface. 

Here are some examples of the types of personal information Fundface collects and how Fundface may use it:

• When you become a Client of Fundface (or its subsidiaries, respectively), Fundface, or Fundface’s  external service provider may collect personal information. The following information may be collected: your name, date of birth, driver number, personal ID or passport, address, phone, email, full bank account details, tax or corporate identification number, company legal status, information that Fundface needs for establishing the controlling person of operating legal entities and partnerships or regarding the identity of the beneficial owner of non-operating entities or information regarding individuals with signatory powers (first and last name, address, email, curriculum vitae), or authorised traders (first and last name, nationality, date of birth, etc.). Fundface will use this information to fulfil your requests and provide the relevant Services.
•  Whenever you contact Fundface or respond to Fundface’s  communications (e.g., email, telephone, in writing), Fundface will receive your contact information and any other personal information you choose to provide Fundface. Fundface will use such information to fulfil your requests or to provide Services.

How personal information is used

Fundface’s  primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. In general, Fundface uses personal information to create, develop, operate, deliver, and improve Fundface’s  Services, content and advertising, and for loss prevention and anti-fraud purposes. Examples of how Fundface may use this information include:

• To provide you with Fundface Services and the client support that you request.
• To process transactions and send notices about your transactions.
• To verify your identity by comparing your personal information against third-party databases.
• To send administrative or account-related information to you.
• To better understand Fundface’s  clients and the way they use and interact with Fundface-owned and/or Fundface-operated websites and Services.
• To provide a personalised experience, and to implement the preferences that you request.
• To customise, measure, and improve Fundface and the content and layout of Fundface’s  website and applications.
• To enhance security, prevent fraud, monitor and verify identity or service access, and to combat spam or other malware or security risks.
• To deliver marketing, service update notices, and promotional offers based on your communication preferences.
• To communicate with you about Fundface’s  events and/or Fundface’s  partner events.
• To prevent and investigate potentially prohibited or illegal activities, and/or violations of Fundface’s  posted user terms.
• To resolve disputes, collect fees, and troubleshoot problems.
• To comply with legal obligations.
• To enforce Fundface’s  agreements with third parties.
• For quality control and staff training.

Fundface will not use your personal information for purposes other than those Fundface has disclosed to you without your permission. From time to time, Fundface may request your permission to allow Fundface to share your personal information with third parties. You may choose not to have your personal information shared with third parties where Fundface relies on consent as the lawful basis for processing your personal information. You may also choose not to allow Fundface to use your personal information for any purpose that is incompatible with the purposes for which Fundface originally collected it or subsequently obtained your authorisation. If you choose to limit the use of your personal information, certain features or Fundface Services may not be available to you.

Information from third party sources

From time to time, Fundface may obtain information about you from third party sources as permitted by applicable law, such as public databases and ID verification partners: Fundface obtains information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publically available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. The legal basis for such processing is to comply with Fundface’s legal obligations, such as anti-money laundering laws. In some cases, Fundface may process additional data about you based on public interest grounds to ensure Fundface’s Services are not used fraudulently or for other illicit activities.
 Fundface also processes such information to provide support to you as part of Fundface’s contractual obligations to you. Lastly, Fundface processes such information in the public interest because it helps Fundface monitor, prevent, and detect fraud.
 Once Fundface obtains such information from third parties, Fundface will not subsequently share it with any other third parties except as described in this Privacy Policy. This information is shared with Fundface’s  processors and corporate group, as necessary, to perform the Services. 

Collection and use of information collected automatically 

Fundface receives and stores certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information does not necessarily reveal your identity directly, but may include information about the specific device you are using, such as the hardware model, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer), and your Internet Protocol (IP) address/MAC address/device identifier.
 For example, Fundface automatically receives and records information on Fundface’s server logs from your browser, including how you came to and used the Services; your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g., country or city-level location), and other technical data collected through cookies, pixel tags, and other similar technologies that uniquely identify your browser. Fundface may also collect information about how your device has interacted with Fundface’s website, including pages accessed and links clicked. Fundface may use identifiers to recognise you when you arrive at the website via an external link, such as a link appearing on a third party site.
 Please refer to the Fundface Cookie Policy (http://fundface.org …) for more information about Fundface’s  use of cookies. 

How Fundface protects and stores personal information

Fundface understands how important your privacy is, which is why Fundface maintains (and requires its service providers to maintain) appropriate physical, technical, and administrative safeguards to protect the security and confidentiality of the personal information you entrust to Fundface.
 Fundface may store and process all or part of your personal and transactional information, including certain payment information, in Trinidad and Tobago, and elsewhere in the world, where Fundface’s service providers are located. Fundface protects your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
 For example, Fundface uses computer safeguards such as firewalls and data encryption, Fundface enforces physical access controls to Fundface’s buildings and files, and Fundface authorises access to personal information only for those employees who require it to fulfil their job responsibilities.
 However, Fundface cannot guarantee that loss, misuse, unauthorised acquisition, or alteration of your data will not occur. Please recognise that you play a vital role in protecting your own personal information. When registering with Fundface’s Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to notify Fundface immediately if you become aware of any unauthorised access to or use of your account.
 Furthermore, Fundface cannot ensure or warrant the security or confidentiality of information you transmit to Fundface or receive from Fundface by Internet or wireless connection, including email, phone, or SMS, since Fundface has no way of protecting that information once it leaves and until it reaches Fundface. If you have reason to believe that your data is no longer secure, please contact Fundface at the email address, mailing address, or telephone number listed at the end of this Privacy Policy. 

How Fundface protects and stores personal information 

Fundface takes care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. Fundface will never sell or rent your personal information. Fundface will only share your data in the following circumstances:

• Fundface may share your information with service providers under contract who help with parts of Fundface’s  business operations such as marketing and technology services. Fundface’s  contracts require these service providers to only use your information in connection with the services they perform for Fundface, and prohibit them from selling your information to anyone else.
• Fundface shares your information with financial institutions with which Fundface partners to process payments you have authorised.
• Fundface may share your information with companies, or other entities that Fundface plans to merge with or be acquired by. Should such a combination occur, Fundface will require that the new combined entity follow this Privacy Policy with respect to your personal information. You will receive prior notice of any change in applicable policies.
• Fundface may share your information with any third parties where required to do so by applicable law or any court or other authority to which Fundface is subject in any jurisdiction; or Fundface believes in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Fundface Agreements and any other applicable policies.
• Fundface may share your information with other third parties with your consent or direction to do so.

How Fundface share personal information with other parties 

You are entitled to review, correct, or amend your personal information, or to delete that information where it is inaccurate. You may do this by contacting your relationship manager. However, this right is limited where personal information is needed for regulatory purposes.
 If you decide to end your client relationship, Fundface will mark your account in Fundface’s  database as “Closed,” but will keep your account information in Fundface’s  database for a period of time as allowed by applicable law. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personal information will not be used by Fundface for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy. 

Rights in the relation to the use of your personal information 

You have a right of access to the personal information that Fundface holds about you under the Federal Act on Data Protection (and the General Data Protection Regulation) and to some related information. You can also require any inaccurate personal information to be corrected or deleted.
 You can object to Fundface’s use of your personal information for direct marketing purposes at any time, and you may have the right to object to Fundface’s processing of some or all of your personal information (and require them to be deleted) in some other circumstances.
 If you wish to exercise any of these rights, please contact Fundface as set out below. 

Retention of personal information 

Fundface will retain your personal data for as long as is necessary for the purposes of Fundface’s  business relationship with you, to perform Fundface’s  contractual obligations to you, or if longer, as required for legal and regulatory purposes.
 Fundface has established internal policies for the deletion of data from client accounts following termination of a client’s subscription to a Service. 

Changes to this privacy policy 

Fundface may periodically post changes to this Privacy Policy on this page. Fundface encourages you to visit this page often. When required by law, Fundface will notify you of any changes to this Privacy Policy. If Fundface makes any material changes Fundface will notify you by email (sent to the email address specified in your account), or by means of a notice on Fundface’s  Services prior to the change becoming effective.

How to contact us 

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you may contact at any time your client relationship manager, or you may contact Fundface via fundface@gmail.com.