Privacy Policy

1. Introduction

Saintrose Capital ("we," "our," or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, engage with our services, or otherwise interact with us. Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

By accessing or using our services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access our website or use our services.

2. Information We Collect

We may collect and process the following categories of personal information about you:

2.1 Information You Provide Directly

When you engage with our services, complete our contact forms, subscribe to our communications, or otherwise correspond with us, you may provide us with personal information including but not limited to: your name, email address, telephone number, postal address, company name, job title, and any other information you choose to provide in your communications with us.

2.2 Information Collected Automatically

When you access our website, we may automatically collect certain information about your device and your use of our website, including your IP address, browser type and version, operating system, referral source, length of visit, page views, and navigation paths. We collect this information using cookies and similar tracking technologies, as further described in our Cookie Policy section below.

2.3 Information from Third Parties

We may receive personal information about you from third parties, including business partners, marketing partners, social media platforms, data brokers, and publicly available sources. This information may include professional and employment related information, business contact information, and other information relevant to our provision of advisory services.

3. How We Use Your Information

We use the information we collect for various purposes, including:

• To provide, operate, and maintain our advisory and capital raising services
• To respond to your inquiries, comments, or questions and provide customer support
• To send you administrative information, such as updates to our terms, conditions, and policies
• To send you marketing and promotional communications, where permitted by applicable law and in accordance with your preferences
• To personalize and improve your experience on our website
• To analyze usage patterns and trends to enhance our website and services
• To detect, prevent, and address technical issues, fraud, and other illegal activities
• To comply with legal obligations and enforce our terms and conditions
• To carry out due diligence and know your client procedures as required by applicable regulations
• For any other purpose with your consent

4. Legal Basis for Processing

Our legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal information concerned and the specific context in which we collect it. We may process your personal information because:

• We need to perform a contract with you or take steps at your request before entering into a contract
• You have given us consent to do so for a specific purpose
• The processing is in our legitimate interests and is not overridden by your rights
• We need to comply with a legal or regulatory obligation

Where we rely on legitimate interests as the legal basis for processing, we have considered the balance between our own interests and your rights and freedoms. Our legitimate interests include operating and improving our business, providing our services, marketing, and ensuring the security of our systems.

5. Disclosure of Your Information

We may share your personal information in the following circumstances:

5.1 Service Providers

We may share your information with third party service providers who perform services on our behalf, such as web hosting, data analysis, payment processing, email delivery, marketing, and customer service. These service providers are contractually obligated to use your personal information only as necessary to provide services to us and in accordance with this Privacy Policy.

5.2 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our assets, your personal information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

5.3 Legal Requirements

We may disclose your personal information if required to do so by law or in response to valid requests by public authorities, including to meet national security or law enforcement requirements, to protect our rights, privacy, safety, or property, or that of our clients or others.

5.4 Professional Advisors

We may share your information with our professional advisors, including lawyers, accountants, auditors, and insurers, where necessary in the course of the professional services that they render to us.

6. International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. Specifically, our servers and offices are located in Estonia, the United Kingdom, and France, and our service providers may operate in other jurisdictions.

When we transfer personal information from the European Economic Area, the United Kingdom, or Switzerland to other countries, we ensure that appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission, or other lawful transfer mechanisms.

7. Data Security

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

We maintain policies and procedures to address 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 is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the personal information, whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

9. Your Rights

Depending on your location and applicable law, you may have the following rights regarding your personal information:

• Right of Access: You have the right to request copies of your personal information.
• Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• Right to Erasure: You have the right to request that we erase your personal information, under certain conditions.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information, under certain conditions.
• Right to Object to Processing: You have the right to object to our processing of your personal information, under certain conditions.
• Right to Data Portability: You have the right to request that we transfer the information that we have collected to another organization, or directly to you, under certain conditions.
• Right to Withdraw Consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the contact details provided below. We may need to verify your identity before responding to your request. We will respond to your request within the time period required by applicable law.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our website and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

We use cookies for the following purposes:

• Essential Cookies: These cookies are necessary for the website to function properly and cannot be switched off in our systems.
• Analytics Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site.
• Functional Cookies: These cookies enable the website to provide enhanced functionality and personalization.
• Marketing Cookies: These cookies may be set through our site by our advertising partners to build a profile of your interests and show you relevant advertisements on other sites.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.

11. Third Party Links

Our website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.

12. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without verification of parental consent, we take steps to remove that information from our servers. If you believe that we might have any information from or about a child under 18, please contact us.

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

For material changes to this Privacy Policy, we will make reasonable efforts to notify you by email, through a notice on our website, or by other means, in accordance with applicable law.

14. Contact Us

If you have any questions about this Privacy Policy, our data practices, or if you would like to exercise any of your rights, please contact us at:

You also have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information violates applicable law. We would, however, appreciate the opportunity to address your concerns before you approach a supervisory authority, so please contact us in the first instance.