Privacy Policy

AsterAlpine Privacy Notice — Version Date: 2025-03-26

Introduction

AsterAlpine is committed to safeguarding and processing personal information ("PI"), including sensitive personal information ("SPI") in accordance with applicable privacy laws. The entity references "AsterAlpine", "we", "us" or "our" as AsterAlpine Capital, LLC and its subsidiaries collectively functioning as controllers of personal information.

The term "you" or "your" applies to individuals whose information is processed, encompassing investors and representatives with direct or indirect relationships, as well as beneficial owners connected to service provision, transactions, or third-party vendor relationships.

This Privacy Notice outlines the purposes for collecting, using, and disclosing personal information while detailing individual rights regarding that processing. Additional terms governing information collection should be read alongside this notice.

PI We Collect About You

Personal information includes data identifying individuals through information alone or combined with other sources. It excludes non-attributable information where identity has been removed. Sensitive personal information encompasses race, ethnicity, religious beliefs, sexual orientation, political opinions, trade union membership, health information, and biometric data.

Collection categories include:

Identification data: Full name, title, gender, marital status, date of birth, passport number, driving license, national identification number, signature
Contact data: Personal address, telephone number, email address
Electronic Monitoring data: Recording and monitoring electronic communications where legally permitted
Financial data: Account numbers, client reference numbers, account statements, investment history
Marketing, Behavioral and Communications data: Marketing preferences, website usage, portal interactions (detailed in Cookie Notice)
Professional Information data: Position, business address, business telephone, business email
Profile data: Usernames, passwords, investments made, services requested, survey responses
Services data: Payment details, service descriptions provided or received
AsterAlpine Building and Assets Security data: Visit records, CCTV recordings
Technical data: Online service usage, IP address, browser type and version, operating system
SPI: Criminal conviction records (when legally required), dietary requirements, disability information, political affiliations

Collection Methods

Information is collected:

Directly through completed forms and applications
Via organization or entity representatives employed with AsterAlpine
Throughout ongoing relationships when details change or services evolve
From public sources including social media and talent acquisition notifications
From third parties such as credit reference agencies
Through website visits and online service logins
Through derived records of interactions

Unless indicated as optional, requested information is necessary for providing requested products and services. Non-provision may prevent service delivery.

Purpose and Legal Basis for Processing PI

For Account Opening and Relationship Initiation

Processing includes anti-money laundering, anti-terrorism, sanction screening, fraud, and due diligence checks. Categories involve identification, contact, financial, professional information, services data, and SPI. Basis includes contract performance, legal/regulatory obligation, and legitimate interests in preventing criminal activity and unlawful conduct.

For Service Delivery

Processing encompasses liaison with third parties and technology solutions access. Identification data, contact information, financial data, profile data, services data, technical data, marketing communications, and professional information are involved. Basis includes contract performance, regulatory obligation, and legitimate interests in providing quality client services and ensuring fee payment.

For Payment and Collection Management

Identification, contact, financial, professional information, and services data are processed. Basis involves contract performance and legitimate interests in managing payments and recovering owed amounts.

For Relationship Management

Processing includes notifications about terms and privacy notice changes. Information categories encompass identification, contact, profile, marketing communications, and professional data. Basis involves contract performance, regulatory obligation, and legitimate interests in notifying about changes.

For Governmental and Regulatory Interaction

Processing involves identification, contact, financial, services, and professional information. Basis is regulatory obligation and public interest.

For Fraud Detection and Prevention

Processing addresses fraud detection and criminal activity prevention, employee protection, and asset safeguarding. Categories include identification, building security data, contact, electronic monitoring, financial, professional information, profile, services, and technical data. Basis involves regulatory obligation, public interest, and legitimate interests in protecting assets and preventing policy violations.

For Business Management and Protection

Processing supports security improvement, troubleshooting, system maintenance, testing, data hosting, and facilities management. Identification, contact, profile, technical, marketing communications, and professional information are involved. Basis includes regulatory obligation and legitimate interests in efficient, secure business operations.

For Event Invitation and Participation

Processing manages participation in market insights, seminars, and similar events. Information categories include identification, contact, profile, technical, marketing communications, and professional data. Basis involves consent and legitimate interests in maintaining current client records, promoting services, gathering feedback, and improving offerings.

For Marketing Communications

Processing sends marketing communications and service updates, analyzing website platform usage for improvement. Categories encompass identification, contact, profile, technical, marketing communications, and professional information. Basis involves consent and legitimate interests in understanding client perspectives and identifying service improvements.

For Vendor Services

Engagement Processing: Anti-money laundering, anti-terrorism, sanctions, fraud, and background checks. Information includes identification, contact, financial, services, and professional data. Basis involves contract performance, regulatory obligation, legitimate interests in preventing unlawful activities, and public interest.

Payment Management: Processing identification, contact, financial, professional information, and services data. Basis includes contract performance and legitimate interests in payment management and collection.

System Access Management: Managing security, troubleshooting, maintenance, testing, and hosting. Categories include identification, contact, profile, and technical data. Basis involves regulatory obligation and legitimate interests in secure business operations and data security.

To Whom We Disclose Your PI

Information may be disclosed to:

Other AsterAlpine team members
Professional advisors, agents, and contractors providing services
Goods and services providers, intermediaries, brokers, and partners
Competent authorities when required or permitted by law
Potential buyers, transferees, merger partners, and their advisers in connection with business transfers
Credit reference agencies or other organizations that help us to conduct anti-money laundering and anti-terrorist financing checks
Persons authorized by applicable law or regulation

International Transfers and Service Providers

Personal information may transfer internationally to AsterAlpine locations in the USA, Canada, UK, and Mexico. Despite varying privacy law levels, identical security and organizational controls apply globally. Third-party service providers contractually comply with AsterAlpine's processing criteria.

For EEA transfers, protection occurs through EU-adequate country designations or contractual EU-approved clauses ensuring equivalent protection.

Marketing and Opt-Out Rights

Certain jurisdictions require express marketing consent. Universally, individuals may opt-out anytime by clicking electronic opt-out links, contacting usual AsterAlpine representatives, using contact details provided, or exercising cookie-related rights per the Cookie Notice.

Third-Party Marketing and PI Sales

We do not share or sell your PI to third parties for the third party to use for their own marketing or other purposes.

PI Retention

Information processes as long as necessary for collection purposes or to comply with legal, regulatory, accounting, reporting, internal policy requirements, or legal claim establishment or defense.

PI Security

Security measures include:

Staff education and training regarding privacy obligations and social engineering risks
Ongoing confidentiality, integrity, availability, and resilience of processing systems
Timely restoration capability following physical or technical incidents
Administrative and technical access restriction controls
Technological measures including firewalls, industry standard SSL encryption with at least 128-bit key lengths, and anti-virus software
Physical security measures like building access controls
External technical assessments, security audits, and vendor due diligence
Perimeter security
Network segregation

Internet data transmission security cannot be guaranteed. Users should avoid sending personal information through unsecure channels. Transmission security is not guaranteed.

Your Rights

Individuals may have the following processing rights:

Access: Requesting personal information copies and usage/sharing information
Object: Objecting to processing based on legitimate interests, public task performance, or direct marketing
Correction: Requesting information updates or corrections for inaccurate or incomplete data
Erasure: Requesting deletion where no legal, regulatory, or valid processing reason exists
Restriction: Requesting processing restrictions, such as for accuracy disputes or pending objections
Portability: Requesting personal information copies in commonly used electronic formats
Automated decision making: Requesting manual intervention for legal-effect automated decisions

Rights may be exercised by emailing Privacy@AsterAlpine.com or using provided contact details. Applicable law and regulation permit appropriate fees for rights exercise.

Specific information may be requested confirming identity and access authorization. Additional information requests may locate processing-related personal information. Responses follow applicable law timescales. Rights exercise carries no disadvantages.

Contacting Us

The Global Head of Privacy and Data Protection oversees AsterAlpine privacy and data protection compliance. For rights exercise or questions, contact:

The Global Head of Privacy and Data Protection
AsterAlpine Capital, LLC
PO Box 141953, Irving, Texas USA
E-Mail: Privacy@AsterAlpine.com

California residents may call +1 (512) 200-4998.

Complaints

Personal information processing concerns should contact the Global Head of Privacy and Data Protection at Privacy@AsterAlpine.com.

Individuals retain rights to complain to data protection or competent authorities with jurisdiction over privacy law in their residence or work country, or where processing issues arose.

Cookie Notice

Separate Cookie Notice applies.

Linked Websites

This Privacy Notice does not apply to third-party owned or controlled websites or sites displaying AsterAlpine advertisements.

Changes to This Privacy Notice

Modifications may occur. Regular website visits ensure awareness of amendments. Material changes receive appropriate channel communication based on normal contact methods.

Note: Not all privacy laws define SPI; Hong Kong, Singapore, and Canada examples exclude this definition.

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