1.1 This document sets out the Data and Privacy Protection Policy for data collected during the course of the use of the website accessed at www.symvest.com (the “Website”).
1.2 The Website is owned and operated by Symfonie P2P Ltd, a Limited Company formed according to the laws of England and Wales and bearing registration number 08703133 (hereafter, “the “Company”, “We”, “Our” or “Us”). Our registered offices are 3-8 Bolsover St, London W1W 6AB, UK. Our offices are open during normal business hours. We can be contacted by telephone on +44 207 129 3108 and by e-mail at email@example.com.
1.3 Our operating subsidiaries are SymVest, s.r.o and SymCredit, s.r.o. (collectively, Our “Subsidiaries”), both are limited companies formed under the laws of the Czech Republic.
2.1 When You use the Website, We will ask You to provide certain data to Us, Our affiliates, subsidiaries and partner companies, such as Your contact details, demographic information, employment, income, professional qualifications, investment experience and educational history. In the case of individuals and entrepreneurs seeking to raise capital We may collect information about Your business and personal financial circumstances. We or our affiliates, subsidiaries and partner companies may supplement the information You provide Us with information We receive from third parties. We refer to all of this information – both what You provide Us and what We collect from other sources – as Your “Personal Data”.
3.1 The principal purposes for which We, our Subsidiaries and affiliates process and store Your Personal Data are:
• To confirm Your identity in order to create an investment or borrowing account and ensure that You are eligible to use the services provided on the Website.
• To conduct required anti-money laundering checks on You in connection with certain transactions You may conduct via the Website or in Transaction Agreements.
• In the case of individuals, companies or entrepreneurs seeking capital, to verify and approve the disclosures You make to potential investors.
• In the case of investors looking to allocate capital, to confirm that You are eligible to make the relevant investments.
• To monitor, improve and administer the Website and the services provided on the Website.
• To enable us to conduct surveys and aggregate User profiles.
• To provide You with information on selected products and selected services that we think may be of interest to You (unless You have asked Us not to do so).
• To enable Us, Our affiliates and subsidiaries to comply with legal and regulatory obligations.
• To contact You to ensure customer satisfaction in respect of Our role as a Website provider and assist You in getting the best value from Our service.
• To gather Statistical information (IP address and hostname, web browser version, pages visited etc.).
• To make note of the previous website address from which you reached us, including any search terms used.
• To maintain other information submitted in forms, for example if you submit your personal details when requesting a form or providing feedback.
Full details of these purposes are set out in our notification to the Information Commissioner’s Office under the UK Data Protection Act 1998.
3.2 Your Personal Data that is collected by Us or affiliates will be kept confidential by Us and Our affiliates, and we will not disclose it to third parties without your consent. The only exceptions to this are:
• We may disclose certain of your Personal Data to third-party service-providers solely in the course of their provision of services to Us and our affiliates. We will take reasonable precautions to ensure that these service-providers are obligated to keep confidential any of Your Personal Data that they use.
• We may disclose certain of your Personal Data if We are required to do so by law, regulation or the order of court or other legitimate government body or arbitration panel. This includes, among other things, any Personal Data that may be requested by the Financial Conduct Authority, the US SEC or any other applicable regulatory authority and which we are required by law to provide.
• You may be informed in one of the Transaction Agreements that We or our affiliates will disclose certain of your Personal Data in connection with a transaction You conduct through the Website.
• In the event that We intend to enter into a major corporate transaction, such as a sale of control of Our business or a start-up on a stock exchange, We may disclose certain of your Personal Data to potential buyers, underwriters or advisors. If We do this, We will take reasonable precautions to ensure that the recipients of your Personal Data are obligated to keep it confidential.
• We may, from time to time, expand, reduce or sell Our business or our Subsidiaries, and this may involve the transfer of certain divisions or the whole business to other parties.
3.3 Cookies are small pieces of information, stored in simple text files, placed on our computer by a website. Some cookies can be read by the website on your subsequent visits. The information stored in a cookie may relate to your browsing habits on the webpage, or a unique identification number so that the website can “remember” you on your return visit. Other cookies are deleted when you close your browser and only relate to the working of the website. Generally speaking, cookies do not contain personal information from which you can be identified, unless you have furnished such information to the website.
• When you first visit Our Website You will see a message informing You about cookies. If you click the ‘Hide this message’ button, the Website will set a cookie which records your preference.
• The Website sets a cookie when you view or use the ‘Contact us’ form. This cookie does not contain any personal information, but is used to help prevent a security attack called ‘cross-site referral’.
• A cookie is also set to allow the text-resizing and high-contrast buttons to work.
• Cookies from Google may also be set when Google Maps are displayed on this website.
• Most browsers allow you
to turn off cookies or to customise your settings for cookies. To find out how to do this, see the ‘Help’ menu on your browser. Please note that if you turn off cookies or change your settings, some features of Our Website may not work correctly.
4.1 We may make changes to this Data and Privacy Protection Policy from time to time. If We do this, We will post the changed Data and Privacy Protection Policy on the Website and will indicate at the top of this page the date the Data and Privacy Protection Policy were last revised. You understand and agree that your continued use of the Service or the Website after we have made any such changes constitutes your acceptance of the new Data and Privacy Protection Policy.
5.2 If you enter into any Transaction Agreement via this Website the terms of that Transaction Agreement will be governed by the laws specifically referenced in that Transaction Agreement.
The material presented via this website is for informational purposes only. Nothing in this website constitutes a solicitation for the purchase or sale of any financial product or service. Material presented on this website does not constitute a public offering of securities or investment management services in any jurisdiction. Symfonie Capital, LLC is registered with the United States Securities and Exchange Commission as an Investment Advisor pursuant to the Investment Advisors Act of 1940. Our ADV filing is publicly available. © 2014 Symfonie Capital, LLC.
Investing in Peer to Peer loans and startup and early stage companies involves risks, including loss of capital, illiquidity, lack of dividends and dilution, and it should be done only as part of a diversified portfolio. The Investments presented in this website are suitable only for investors who are sufficiently sophisticated to understand these risks and make their own investment decisions. For further information see our discussion of investment risks.