As part of our business operations, we collect personal information from our clients and prospective clients in order to provide them with our products and services, and ensure that we can meet their needs when providing these products and services, as well as when providing them with any respective information.
Your privacy is of utmost importance to us, and it is our policy to safeguard and respect the confidentiality of information and the privacy of individuals. This Privacy Notice sets out how Herd Ventures API products and services provided in Wyoming; and the investment services provided by Herd Ventures, collects, uses and manages the personal information we receive from you, or a third party, in connection with our provision of services to you or which we collect from your use of our services and/or our website. The Privacy Notice also informs you of your rights with respect to the processing of your personal information.
Our Privacy Notice is reviewed regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices are taken into consideration, as well as that it remains abreast of the changing regulatory environment. Any personal information we hold will be governed by our most recent Privacy Notice.
Please note that if you are an employee, a contractor or a third-party provider of Herd Ventures, your personal information will be used in connection with your employment contract or your contractual relationship, whichever applies.
This Privacy Notice applies to the processing activities performed by Herd Ventures to the personal information of its clients and its potential clients and website visitors.
We may amend this Privacy Notice at any time by posting the amended version on this site including the effective date of the amended version. We will announce any material changes to this Privacy Notice on our website.
As used herein, the following terms are defined as follows:
“Herd Ventures Platform Services” means Herd Ventures-branded websites, applications, services, or tools operated by Herd Ventures.
“Personal Information” or “Personal Data” or “your data” refers to any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.
Herd Ventures is your Data Controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards, this Privacy Notice, as well as any applicable national laws. Herd Venture uses encryption to protect your
information and store decryption keys in separate systems. We process and retain your personal information on our servers in multiple data center locations
Herd Ventures respects the privacy of any users who access its website, and it is therefore committed to taking all reasonable steps to safeguard any existing or prospective clients, applicants and website visitors.
Herd Ventures keeps any personal data of its clients and its potential clients in accordance with the applicable privacy and data protection laws and regulations.
We have the necessary and appropriate technical and organizational measures and procedures in place to ensure that your information remains secure at all times. We regularly train and raise awareness for all our employees to the importance of maintaining, safeguarding and respecting your personal information and privacy. We regard breaches of individuals’ privacy very seriously and will impose appropriate disciplinary measures, including dismissal from employment. We have also appointed a Data Protection Officer, to ensure that Herd Ventures manages and processes your personal information in compliance with the applicable privacy and data protection laws and regulations, and in accordance with this Privacy Notice.
The personal information that you provide us with when using our Website, applying for a role with Herd Ventures, is classified as registered information, which is protected in several ways. Registered information is securely stored in a safe location, and only authorized personnel have access to it. All personal information is transferred to Herd Ventures over a secure connection, and thus all reasonable measures are taken to prevent unauthorized parties from viewing any such information. Personal information provided to the Herd Ventures that does not classify as registered information is also kept in a safe environment and accessible by authorized personnel only through username and password.
In order to invest through our website, you must first share required information as when displayed on the website. The information that we collect from you is as follows:
Full name, residential address and contact details (e.g. email address, telephone number, fax etc.);
Date of birth, place of birth, gender, citizenship;
External Wallet Address;
Information on whether you hold a prominent public function (PEP) (like politician);
Verification information, which includes information necessary to verify your identity such as a passport, driver’s licence or Government-issued identity card);
Other Personal Information or commercial and/or identification information – Whatever information we, in our sole discretion, deem necessary to comply with our legal obligations
under various anti-money laundering (AML) obligations, such as under the European Union’s 4th AML Directive and the India Bank Secrecy Act (BSA).
Location Information – Information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform;
Log Information – Information that is generated by your use of Herd Ventures platform Services that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
We obtain information about you in a number of ways through your use of our services, and from information provided in the course of on-going support service communications. We also receive information about you from third parties such as your external wallet holders and through publicly available sources. For example:
The wallets you use to transfer funds to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your wallet details;
Your business partners may provide us with your name and address, as well as financial information;
Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our website;
Credit reference agencies do not provide us with any personal information about you, but may be used to corroborate the information you have provided to us.
Once you start using our Services or subscribe to information, we must use your personal information to perform our services and comply with our obligations to you. It is also in our legitimate interests to try to ensure that we are providing the best products and services so we may periodically review your needs based on our assessment of your personal information to ensure that you are getting the benefit of the best possible products and services from us.
We may, from time-to-time, use personal information provided by you through your use of the services and/or through client surveys to help us improve our products and services. It is in our legitimate interests to use your personal information in this way to try to ensure the highest standards when providing you with our products and services and to continue to be a market leader within the financial service industry.
We may need to use personal information collected from you to investigate issues or to settle disputes with you because it is our legitimate interest to ensure that issues and disputes get investigated and resolved in a timely and efficient manner.
We may need to use your personal information to comply with any applicable laws and regulations, subpoenas, court orders or other judicial processes, or requirements of any applicable regulatory authority. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.
From time to time, we may send you surveys as part of our client feedback process. It is in our legitimate interest to ask for such feedback to try to ensure that we provide our products and services at the highest standard. However, we may from time to time also ask you to participate in other surveys and if you agree to participate in such surveys we rely on your consent to use the personal information we collect as part of such surveys. All responses to any survey we send out whether for client feedback or otherwise will be aggregated and depersonalized before the results are published and shared.
Our website pages and emails may contain web beacons or pixel tags or any other similar types of data analysis tools that allow us to track receipt of correspondence and count the number of users that have visited our webpage or opened our correspondence. We may aggregate your personal information with the personal information of our other clients on an anonymous basis (that is, with your personal identifiers removed), so that more rigorous statistical analysis of general patterns may lead us to providing better products and services.
If your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. If your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.
We may use your personal information to send you marketing communications by email or other agreed forms (including social media campaigns), to ensure you are always kept up-to-date with our latest products and services. If we send you marketing communications we will do so based on your consent and registered marketing preferences.
We may need to process your personal information for internal business and research purposes as well as for record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations. This may include any communications that we have with you in relation to the products and services we provide to you and our relationship with you. We will also keep records to ensure that you comply with your contractual obligations pursuant to the agreement (‘Terms of Service”) governing our relationship with you.
Often the law requires us to advise you of certain changes to products or services or laws. We may need to inform you of changes to the terms or the features of our products or services. We need to process your personal information to send you these legal notifications. You will continue to receive this information from us even if you choose not to receive direct marketing information from us.
Herd Ventures will not disclose any of its clients’ confidential information to a third party, except: (a) to the extent that it is required to do so pursuant to any applicable laws, rules or regulations; (b) if there is a duty to disclose; (c) if our legitimate business interests require disclosure; (d) in line with our Terms of Service; (e) at your request or with your consent or to those described in this Privacy Notice. Herd ventures will endeavor to make such disclosures on a “need-to-know” basis, unless otherwise instructed by a regulatory authority. Under such circumstances, Herd ventures will notify the third party regarding the confidential nature of any such information.
As part of using your personal information for the purposes set out above, Herd ventures may disclose your personal information to the following:
Any members of Herd ventures, which means that any of our affiliates and subsidiaries may receive such information;
Any of our service providers and business partners, for business purposes, such as specialist advisors who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, IT, debt-recovery, analytics, research or other services;
If Herd ventures disclose your personal information to service providers and business partners, in order to perform the services requested by clients, such providers and partners may store your personal information within their own systems in order to comply with their legal and other obligations.
We require that service providers and business partners who process personal information to
acknowledge the confidentiality of this information, undertake to respect any client’s right to privacy and comply with all relevant privacy and data protection laws and this Privacy Notice.
Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers and business partners store and process your personal data in Wyoming and elsewhere in the world.
Under certain circumstances, we may be required to disclose your personal information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
We may transfer your personal information outside Wyoming to other Company subsidiaries, service providers and business partners (i.e Data Processors) who are engaged on our behalf. To the extent that we transfer your personal information outside of Wyoming, we will ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with the GDPR General Data Protection Act 2016. If transfers of personal information are processed in the US, we may in some cases rely on applicable standard contractual clauses, binding corporate rules.
If you are a data subject for purposes of the GDPR, you have a number of important rights, including rights to:
Fair processing of information and transparency over how we use your use personal information;
Access to your personal information and to certain other supplementary information that this Policy is already designed to address;
Require the correction of any mistake in the personal information that we hold about you;
Require the erasure of personal information concerning you in certain situations;
Receive the personal information concerning you that you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party in certain situations;
Object at any time to the processing of your personal information for direct marketing;
Object to decisions being taken by automated means that produce legal effects concerning you or similarly significantly affect you;
Object in certain other situations to our continued processing of your personal information; and
Otherwise restrict our processing of your personal information in certain circumstances.
For further information on each of these rights, including the circumstances in which they apply, guidance is available from applicable data protection authorities.
By using our products and services, you consent to your Personal Data being transferred to other countries, including countries that have differing levels of privacy and data protection laws than your
country. In all such transfers, we will protect your personal information as described in this Privacy Notice, and ensure that appropriate information sharing contractual agreements are in place.
Safeguarding the privacy of your personal information is of utmost importance to us, whether you interact with us personally, by phone, by email, over the internet or any other electronic medium. We will hold personal information, for as long as we have a business relationship with you, in secure computer storage facilities, and we take the necessary measures to protect the personal information we hold from misuse, loss, unauthorized access, modification or disclosure.
When we consider that personal information is no longer necessary for the purpose for which it was collected, we will remove any details that will identify you or we will securely destroy the records. However, we may need to maintain records for a significant period of time (after you cease being our client). For example, we are subject to certain anti-money laundering laws which require us to retain the following, for a period of 7 years after our business relationship with you has ended.
A copy of the records we used in order to comply with our client due diligence obligations;
Supporting evidence and records of transactions with you and your relationship with us.
Also, the personal information we hold in the form of a recorded information, by telephone, electronically or otherwise, will be held in line with local regulatory requirements (i.e. 7 years after our business relationship with you has ended or longer if you have legitimate interests (such as handling a dispute with you)). If you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications.
We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons.
When you use our products and services, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used when engaging with us. We use Cookies to (i) help us recognize you as a customer, collect information about your use of our products and services, to better customize our services and content for you, and to collect information about your computer or other access devices to ensure our compliance with our AML obligations.
The rights that are available to you in relation to the personal information we hold about you are outlined below.
If you ask us, we will confirm whether we are processing your personal information and, if so, what information we process and, if requested, provide you with a copy of that information within 30 days from the date of your request.
It is important to us that your personal information is up to date. We will take all reasonable steps to make sure that your personal information remains accurate, complete and up-to-date. If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your personal information to others, we will let them know about the rectification where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your personal information so that you can contact them directly.
You may inform us at any time that your personal details have changed by emailing us at Herd Ventures will change your personal information in accordance with your instructions. To proceed with such requests, in some cases we may need supporting documents from you as proof i.e. personal information that we are required to keep for regulatory or other legal purposes.
You can ask us to delete or remove your personal information in certain circumstances such as if we no longer need it, provided that we have no legal obligation to retain that data. Such requests will be subject to the contract that you have with us, and to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have disclosed your personal information to others, we will let them know about the erasure request where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your personal information so that you can contact them directly.
You can ask us to block or suppress the processing of your personal information in certain circumstances such as if you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information. We will inform you before we decide not to agree with any requested restriction. If we have disclosed your personal information to others, we will let them know about the restriction of processing if possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your personal information so that you can contact them directly.
In certain circumstances you might have the right to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to re-use it elsewhere or ask us to transfer this to a third party of your choice.
You can ask us to stop processing your personal information, and we will do so, if we are:
Relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
Processing your personal information for direct marketing; or
Processing your personal information for research unless we reasonably believe such processing is necessary or prudent for the performance of a task carried out in the public interest (such as by a regulatory or enforcement agency).
If we have made a decision about you based solely on an automated process (e.g. through automatic profiling) that affects your ability to access our products and services or has another significant effect on you, you can request not to be subject to such a decision unless we can demonstrate to you that such decision is necessary for entering into, or the performance of, a contract between you and us. Even if a decision is necessary for entering into or performing a contract, you may contest the decision and require human intervention. We may not be able to offer our products or services to you, if we agree to such a request (i.e. end our relationship with you).
Our Privacy Notice is reviewed regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices are taken into consideration, as well as that it remains abreast of the changing regulatory environment. Any personal information we hold will be governed by our most recent Privacy Notice.
If we decide to change our Privacy Notice, we will post those changes to this Privacy Notice and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
Our products and services are not directed to persons under the age of 18, hereinafter “Children”, “Child” and we do not knowingly collect personal information from Children. If we learn that we have inadvertently gathered personal information from a Child, we will take legally permissible measures to remove that information from our records. If you are a parent or guardian of a Child, and you become aware that a Child has provided personal information to us, please contact us and you may request to exercise your applicable access, rectification, cancellation, and/or objection rights.
Any questions, complaints, comments and requests regarding this Privacy Notice are welcome and should be addressed to our support.
We respect your privacy and we are committed to ensuring that you are adequately informed on how you can manage your cookies.
Cookies are small data files. When you visit a website, the website sends the cookie to your computer. Your computer stores it in a file located inside your web browser.
Cookies do not transfer viruses or malware to your computer, because the data in a cookie does not change when it travels back and forth, it has no way to affect how your computer runs. Instead they act more like logs (i.e. they record user activity and remember stateful information), and get updated every time you visit a website.
We may obtain information about you by accessing cookies sent by our website. Different types of cookies keep track of different activities. For example, session cookies are used only when a person is actively navigating a website. Once you leave the website, the session cookie disappears. For a more detailed list of cookies we use, please see the relevant section below.
Why are Cookies useful?
We use functional cookies to analyse how visitors and clients use our website, as well as track and improve our website’s performance and function. This allows us to provide a high-quality customer experience by quickly identifying and fixing any issues that may arise. For example, we might use cookies to keep track of which website pages are most popular and which method of linking between website pages is most effective.
In addition, functional cookies for example, are used to allow us to remember your preferences and identify you as a user, ensure your information is secure and operate more reliably and efficiently. For example, cookies save you the trouble of typing in your username every time you access our trading platform, and recall your preferences.
Here are some of the functions our cookies provide us with:
Types of Cookies we use