Privacy Policy

Last updated: 2024-12-19

1. Information We Collect

We collect information that you provide directly to us, including when you create an account, submit investor profiles, complete KYC verification, and use our services.

This may include:

  • Name, email address, and contact information
  • Investor profile and eligibility information
  • KYC/KYB documentation and verification data
  • Indications of interest and listing information
  • Transaction facilitation records (documentation, settlement coordination)

Eligibility Verification: As a restricted-access platform for eligible, professional, and sophisticated investors, we collect detailed information to verify your eligibility status. This includes financial information, professional qualifications, and regulatory status as required by applicable laws.

KYC/AML Requirements: Identity verification and source-of-funds checks arestandard requirements for all participants. Our compliance team conducts screening for Politically Exposed Persons (PEP), sanctions, adverse media, and fraud signals as part of our anti-money laundering (AML) obligations. This includes:

  • Identity verification documents (government-issued ID, proof of address)
  • Source-of-funds documentation and verification
  • Screening against sanctions lists, PEP databases, and adverse media
  • Fraud and risk assessment checks

KYC/AML screening is a standard expectation for all participants and is required before you can submit indications of interest on listings.

2. How We Use Your Information

We use the information we collect to:

  • Provide, maintain, and improve our bulletin-board marketplace services
  • Verify investor eligibility and compliance with access restrictions
  • Conduct KYC/AML screening, including identity verification and source-of-funds checks
  • Screen for PEP, sanctions, adverse media, and fraud signals
  • Facilitate deal-desk assisted workflow and coordination between buyers and sellers
  • Process indications of interest and manage listings
  • Coordinate transaction documentation and settlement (off-platform)
  • Comply with legal and regulatory requirements, including KYC/KYB and AML obligations
  • Send you technical notices and support messages

Restricted Access Model: Your eligibility information is used to enforce our restricted-access model, ensuring only eligible, professional, and sophisticated investors can participate in platform activities.

3. Data Security

We implement appropriate technical and organizational measures to protect your personal information. This includes encryption, access controls, and regular security audits. Given the sensitive nature of investor eligibility and financial information, we maintain enhanced security measures appropriate for a financial services platform.

4. Data Sharing and Disclosure

We may share your information with:

  • Our deal desk team to facilitate discussions and coordinate transactions
  • Regulatory authorities as required by law
  • Service providers who assist in platform operations (under strict confidentiality agreements)
  • Issuers and their representatives, when necessary for consent and ROFR processes

We do not sell your personal information. Information is shared only as necessary to provide our services and comply with legal obligations.

5. Data Retention

We retain your personal information for as long as necessary to provide our services and comply with legal obligations, including regulatory record-keeping requirements. Given the nature of our platform and regulatory requirements, some information may be retained for extended periods as required by applicable securities and financial services regulations.

6. Your Rights

Under applicable data protection laws (including GDPR for EU/EEA users), you have the right to:

  • Access your personal information
  • Rectify inaccurate or incomplete information
  • Erase your personal information (subject to legal retention requirements)
  • Restrict processing of your personal information
  • Data portability
  • Object to processing

Please note that some information may be retained as required by regulatory obligations, even if you request deletion.

7. Contact Us

For questions about this Privacy Policy or to exercise your data protection rights, please contact us at privacy@tranchebook.com.