Privacy Policy

Privacy Policy

Everywhere in this Privacy Notice:

  • “33 Capital”, “we”, “us”, and “our” mean 33 Capital Management LLC.
  • “You” and “your” refer to the individual who the personal data is about.
  • “Process” and “processing” mean all the actions that 33 Capital performs on your personal data, including collection, use, sharing, securing, and eventual destruction.
  • “Personal data” or “data” is any information that does, or could, identify you.
  • “Special categories” of data means particularly sensitive data like that concerning health, sex life, ethnic origin, and criminal offences.
  1. INTRODUCTION AND SCOPE

33 Capital understands that you provide your data to us in the expectation that we will protect it, treat it as confidential, and allow you to exercise your rights over it. This Privacy Notice describes how we process your data and how you can exercise your rights.

This Notice is addressed principally to our customers and clients and to prospective clients. The Notice does not, however, apply to 33 Capital’s employees and contractors.

Unless otherwise stated, this Notice applies globally, regardless of your geographical location.

  1. CHANGES TO THIS NOTICE

We may update this Notice from time to time and will tell you about material changes through the most effective channel, usually the e-mail address we hold for you. The Notice was last updated on October 15th, 2024.

  1. PERSONAL DATA COLLECTED

In nearly all circumstances, the data we process about you is provided by you yourself, or collected with your explicit authorization. This data is collected, for example, on online and paper forms. 33 Capital is aware of the sensitive nature of this data and of our duty to protect it.

By providing my contact information, I acknowledge and give my explicit consent to be contacted via SMS and receive emails for various purposes, which may include marketing and promotional content. Message and data rates may apply. Message frequency may vary. Reply STOP to opt out. Refer to our Privacy Policy for more information.

We also collect data about you when you interact with us online. We collect this data using cookies and other standard online technologies. Cookies allow us to recognize your device. We collect information about how you use our website, for example what pages you visited and how long you stayed on them.

  1. PURPOSES OF PROCESSING

We use your personal data first and foremost to provide our services to you, for example to:

  • Respond to your inquiries
  • Carry out standard business functions like invoicing and online authentication

We use your data to help us improve our services and online experiences, for example to identify which parts of our website our visitors find useful. Usually, the data used for this purpose is not directly attributable to you as an individual.

Marketing: We may use your data to contact you about our services and business after you have indicated an interest in them. When required by your local law, we will obtain your prior consent. See Section 8, Your Privacy Rights for information about exercising your marketing preference

  1. RECIPIENTS OF YOUR DATA

In order to achieve the purposes described above, 33 Capital may disclose your data to various individuals and organizations:

  • Our employees and contractors who have a “need to know” and who have signed a confidentiality agreement covering your data as a condition of their employment with us.
  • Service providers (“processors”) who process your data on our behalf and per our instructions; for example, our Cloud storage provider, CRM software-as-a-service vendor, and web marketing services company. These service providers are contractually bound to protect your data to the same standard as 33 Capital and are prohibited from using it for their own purposes.
  • Your data may be transferred to third parties as a result of a merger, acquisition, or similar corporate event involving 33 Capital.
  • We will disclose your personal data if compelled by law.

33 Capital will never sell your personal data or otherwise disclose it for commercial gain.

  1. DATA SECURITY

33 Capital employs—and continually reviews—administrative, technical, and physical security measures appropriate to the sensitive nature of the personal data that you provide to us. These measures include, for example, firewalls, roles-based access, and current security patches. It is, however, impossible to guarantee that personal data will never be accidentally or illegally breached.

  1. DATA RETENTION

In principle, we store your data for the period of your relationship with us and thereafter only as necessary to satisfy legal, accounting, and other obligations or to resolve disputes.

Please note that our data retention policy does not affect your right (see Section 8) to request erasure of the data that we hold about you.

  1. YOUR PRIVACY RIGHTS

You may at any time request:

  1. Access to the data that we hold about you
  2. Correction of inaccuracies in the data
  3. That we cease to process the data
  4. That we delete the data
  5. Information about data portability

When we process your data based on your consent, you may withdraw that consent at any time.

You can make these requests and take these actions using the contact information provided in Section 10.

Marketing: We strive to ensure that our marketing communications are only received by individuals with an interest in our services. When required by your local law, this means obtaining your prior consent. However, if you receive unwanted marketing messages from us, please use the opt-out mechanism, if available, or contact us so that we can remove you from our marketing list.

If you believe that we have infringed your privacy rights, please contact us so that we can try to resolve the issue. However, if you are an EU resident, you have the right to lodge a complaint with your local supervisory authority.

How Do We Share Your Mobile Information?

No mobile information will be obtained from and/or shared with third parties or affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. You can always decline or stop receiving messages by responding “STOP” at any time. For more information, reply ‘HELP’. Message and data rates may apply. Message frequency varies.

  1. CONTACT US

Privacy enquiries can be sent to: IR@33CapitalManagement.com

203.391.9340

33 Capital Management

1 E Putnam Ave 2nd Floor

Greenwich, CT 06830