This is the privacy policy (“Privacy Policy”) that governs how we, the funds of Hanaco (“Hanaco”, “we”, “our” or “us”), use Personal Information (defined below) that we collect, receive and store about individuals in connection with the use of the website www.hanacovc.com, and any other website that we operate (each, together with its sub-domains, content and services, a “Site”). This Privacy Policy also applies in connection with Personal Information we receive through the Site or other communication channels (such as, electronic, written or any oral communications). We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our private information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Site or other communication channels with Hanaco.
“Personal Information”. Means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, telephone number, tax information, bank account details or other contact and/or financial information.
Terms of Use. This Privacy Policy is a part of our Terms of Use. Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.
Consent and Modification. You are not legally obligated to provide us with Personal Information, and you hereby confirm that providing us with Personal Information is at your own free will. By using the Site or providing the Personal Information to Hanaco though other communication channels, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Site, and your continued use of the services thereafter shall mean that you accept such changes
Cookies and Other Tracking Technologies
. Our Site may utilize “cookies”, anonymous identifiers and other tracking technologies in order for us to present you with information that is customized for you. A “cookie” is a small piece of code that may be used to collectIf you are one of our existing or potential portfolio companies, you may send us basic contact information (including, names, surnames, job titles and benefits, email addresses and phone numbers) as well as documents and presentations related to the topic you would like to discuss with us, as well as other information which includes Personal Information. We will process such Personal Information for the purpose of maintaining our communication and business relations with you, to provide our services to you, to enter and/or perform any contractual rights and obligations under any agreement with you/our organizational and operational documents.
If you are an existing or potential investor, we collect certain information such as your name, company name, email address, personal profile, home or other physical address, telephone number, tax status/forms, bank account details or other contact and/or financial information for the purpose of your admission to any of the funds of Hanaco, maintaining our communication and business relations with you, providing our services to you, entering and/or performing any contractual rights and obligations under any agreement with you/our organizational and operational documents or any other transaction that you are doing with Hanaco. We may ask you to complete questionnaires and/or other kinds of forms and any other information that you decide to provide us.
As an existing investor, you will be added to our web portal for investors whereby you receive certain information regarding your investments in Hanaco funds. Please note that we work with service providers who assist us with the provision of such initiatives, and they may also be exposed to your Personal Information. By engaging in these initiatives, to the maximum extent permitted by law, you consent to the transfer of your Personal Information to such service providers. In such a case, Hanaco will use your Personal Information in accordance with this Privacy Policy.
You only submit information which is relevant and accurate with respect to the topic you would like to discuss with us; Your Personal Information and other information you provide us with does not and shall not violate, breach or infringe any third party right or applicable law; You have displayed all the required privacy policies, and have all the required permissions from, all the relevant individuals mentioned in, or related to, the Personal Information or such other information to permit Hanaco to use the Personal Information and the information included therein in accordance with this Privacy Policy.
In addition to the Personal Information and purposes described in each section above, we collect Personal Information and any other data you decide to provide us with for the purposes of:
We generally do not disclose your Personal Information, we may however:
Share your Personal Information with our third-party service providers to comply with applicable law, regulation, legal process or governmental request, to comply with Hanaco’s agreements with its service providers in connection with such legal requirements, and to complete our business transactions. Such information may be transferred to other countries, according with applicable law.
Transfer your Personal Information to our funds, entities and/or affiliates for the purpose of storing or processing such information on our behalf in accordance with this Privacy Policy. Such information may be transferred to other countries, according with applicable law.
Disclose your Personal Information or any information you submitted through the Site or other communication channels if we have a good faith belief that the disclosure of such information is helpful or reasonably necessary to: (1) comply with any applicable law, regulation, legal process or governmental request; (2) enforce our Terms, including investigations of potential violations thereof; (3) detect, prevent, or otherwise address fraud or security issues; or (4) protect against harm to the rights, property or safety of Hanaco, our users, yourself or the public.
Transfer or assign your Personal Information in connection with any changes made to the structure of Hanaco or any of its funds, including by any merger, acquisition, reorganization, liquidation, dissolution, consolidation or any other corporate change.
We may use information which does not enable identification of an individual user, such as aggregated information about the use of our Site or disclose it to third party service providers in order to improve our Site and enhance your experience with the Site. We may also disclose such information (with or without compensation) to third parties, including advertisers and partners.
Opting Out/deletion of Personal Information. You may choose not to receive future promotional, advertising, or other Site-related emails from us by selecting an unsubscribe link at the bottom of each email that we send. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative emails that are necessary to facilitate your use of the Site. We will deal with all deletion requests in accordance with applicable law. We reserve the right to delete any information provided to Hanaco at our entire discretion.
Choice. At all times, you may choose whether or not to provide or disclose Personal Information. If you choose not to provide mandatory Personal Information, you may still visit parts of the Site, but you may be unable to access certain options, programs, offers, and services in connection with our interaction with you.
Access/Accuracy. To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may submit an access request by sending an email to gabi@hanacovc.com. Your email should include adequate details of your request. You may have certain rights under applicable law with respect to your Personal Information. These rights include: (i) the right to access and review your own Personal Information; (ii) to request that we rectify any information we hold about you that is inaccurate or misleading; (iii) the right to object, or to request restriction of the processing of your Personal Information; (iv) to request that decisions made about you that will not solely be based on processing by automated means; (v) to request to stop the processing of your Personal Information for direct marketing purposes; and (vi) a right to lodge a complaint with the applicable data protection supervisory authority. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
Links to and Interaction with Third-Party Products. The Site may enable you to interact with, or may contain links to, other third-party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third-Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third-Party Service that you choose to use or interact with.
Children’s Privacy. The Site is not structured to attract children under the age of 18 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years. If we learn that we have collected Personal Information from a child under 18 years, we will generally delete that information as quickly as possible. If you believe that we might have any such information, please contact us at gabi@hanacovc.com.
Security. The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use reasonable acceptable means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security, you can contact us at gabi@hanacovc.com.
Commitment. We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly updating our Service to meet these demands. If you have any comments or questions regarding our Privacy Policy, or your Personal Information that we may be storing and using, please contact us at gabi@hanacovc.com. Individuals who believe that their rights under the Data Protection Law, 2017 of the Cayman Islands have been infringed, have a right to complain to the Office of the Cayman Islands Ombudsman (https://ombudsman.ky).