Your Privacy Is Important to GVRR Capital

In the course of serving our clients, GVRR Capital may obtain personal information about such clients. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy.

The Sources of Information

The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to GVRR Capital during the course of your relationship with us. We may also collect information about your transactions and experiences with GVRR Capital relating to the services GVRR Capital provides. In addition, depending on the services you require, GVRR Capital may obtain additional information about you, such as your credit history, from consumer reporting agencies.

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. e-mail monitoring). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

The Information We Have About You

If you deal with GVRR Capital in your individual capacity (e.g. as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you may include (in addition to any other information as may be determined on a case-by-case basis):

• Your full name, phone number, email address, organization, and other contact details;
• Extensive financial information, including the source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources; and
• A personal identifier such as depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about our clients is accurate, complete, and up to date, we rely on our clients promptly notifying us if there are any changes to their personal information.

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about our clients is accurate, complete, and up to date, we rely on our clients promptly notifying us if there are any changes to their personal information.

Our Use of Your Personal Information

We may use your personal information to:

• Administer, operate, facilitate and manage your relationship and/or account with GVRR Capital. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;
• Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by GVRR Capital; and
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with GVRR Capital ends, GVRR Capital will continue to treat your personal information, to the extent we retain it, as described in this policy.

Disclosures of Your Personal Information within GVRR Capital

In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within GVRR Capital may be given, or given access to, your personal information. For example, one GVRR Capital entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as the US and international brokerage, asset management, and advisory services. When sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within GVRR Capital is provided below, under Information Security: How We Protect Your Privacy.

Disclosures of Your Personal Information to Third Parties

GVRR Capital does not disclose your personal information to third parties, except as described in this policy. Third-party disclosures may include sharing such information with investment partners (e.g. deal sponsors), other financial institutions (e.g. lenders requiring such information pursuant to regulatory requirements), and/or non-affiliated companies that perform support services for your account or facilitate your transactions with GVRR Capital, including those that provide professional, legal or accounting advice to GVRR Capital. Each such third party is required to maintain the confidentiality of such information to the extent received and to use your personal information only in the course of providing the services, and only for the purposes, dictated by GVRR Capital.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners, or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.

You should know that GVRR Capital will not sell your personal information.

Information Security: How We Protect Your Privacy

GVRR Capital is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized GVRR Capital employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, third parties are held to stringent standards of privacy. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification, and unauthorized access or disclosure. Some of the other central features of our information security program are:

• A dedicated group within GVRR Capital that designs, implements, and provides oversight to our information security program;
• The use of specialized technology such as firewalls;
• Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities in the technology;
• Internal and external reviews of our Internet sites and services;
• Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
• Implementing controls to identify, authenticate and authorize access to various systems or sites;
• Protecting information during transmission through various means including, where appropriate, encryption; and
• Providing GVRR Capital personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

Privacy and the Internet

The following additional information will be of interest to you as a visitor to this site:

• Users of GVRRCapital.com are required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password.
• com is built upon a secure infrastructure with multiple layers of protection. GVRR Capital uses industry-standard encryption technologies to protect your information from external compromise.
• Security is a cooperative effort between GVRR Capital and the users of GVRRCapital.com. Please remember that your login and password are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.
• We may collect certain aggregate and non-personal information when you visit GVRRCapital.com. We may collect this information through “cookie” technology. Cookies are bits of text that can be placed on your computer’s hard drive when you visit certain websites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website. The “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember, though, without cookies, you may not be able to take full advantage of all of the GVRRCapital.com features.
• “Clickstream” data (e.g., information regarding which of our Web pages you access, the frequency of such access, and your product and service preferences) may be collected by GVRR Capital itself, or by our service providers, use cookies, Web beacons, page tags, or similar tools that are set when you visit our Web site or when you view an advertisement we have placed on another Web site. Clickstream data and similar information may be shared internally within GVRR Capital and used: for administrative purposes; to assess the usage, value, and performance of our online products and services; to improve your experience with our Web sites; and as otherwise permitted by applicable law or regulation. If you are a GVRR Capital client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions.
• GVRR Capital may make available on this Web site third-party applications such as content linking or sharing facilities. Information collected by providers of such applications is governed by their privacy policies.
• Our Web sites are not currently configured to respond to “do not track” signals or similar mechanisms.

Information For EEA Users (EU plus Iceland, Norway, and Liechtenstein)

What Rights Do I Have?

Where GVRR Capital is a Controller of data under the EU’s new General Data Protection Regulation (GDPR), individuals located in the European Economic Area (EEA) will have additional rights with respect to their non-public personal information (NPI), including the right of access, rectification, restriction, opposition, erasure, and data portability (each, as defined by the GDPR). Where possible, we obtain and rely on user consent as a lawful basis for processing personal data. In some cases, GVRR Capital may process and retain NPI pursuant to a legal obligation or another legitimate interest under the GDPR to protect your vital interests, the interests of GVRR Capital, or those of another person.

How May I Exercise My Individual Rights?

Users located within the EEA may contact our Data Protection Officer with questions or requests regarding their NPI using the contact information below. Please note that GVRR Capital may request additional information from you to verify your identity before we disclose any personal or account information. You may opt-out of receiving promotional communications at any time by following the “unsubscribe” instructions found within GVRR Capital email updates or changing your contact preferences. Please note, you will continue to receive essential account-related information, even if you unsubscribe from promotional emails.

Who Can I Contact at GVRR Capital Regarding Data Protection Issues?

GVRR Capital has designated a Data Protection Officer to assist with data privacy and data protection issues. You may contact him/her by emailing info@gvrrcapital.com and addressing your questions or concerns to the Data Protection Officer.

Other Privacy Policies or Statements; Changes to Policy; Contact

This policy provides a general statement of the ways in which GVRR Capital protects your personal information. You may, however, in connection with specific products or services offered by GVRR Capital, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. If you require further information regarding our privacy policies and practices please contact  info@gvrrcapital.com.

Statement on Cookies

By using our Website with your browser settings adjusted to accept cookies, you consent to GVRR Capital’s use of cookies and other tools to provide the products and services available on our site. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to Managing Cookies below.

Cookies at GVRR Capital and How We Use Them

Cookies are small text files that may be placed on your Web browser when you visit our Website or when you view advertisements we have placed on other websites. Cookies allow your browser to remember some specific information that the web server can later retrieve and use. GVRR Capital does not use cookies to store any personal information that could be read or understood by others. When you quit your browser, some cookies are stored in your computer’s memory, while some expire or disappear.

Cookies are used primarily for administrative purposes, to improve your experience with our Website. Examples of this include the use of cookies:

• To improve site security by “authenticating” you (i.e., verify that you are who you say you are) when you sign in to our site.
• To keep track of your specified preferences such as language, time zone, and timeouts after periods of inactivity.
• To allow you to navigate our sites more easily by “remembering” your identity so that you do not have to input your password multiple times as you move between pages or services.

In addition to administrative uses, GVRR Capital may also use cookies in one or more of the following ways:

• To conduct research and analytics to improve our Website and our products and services. This includes compiling statistical information concerning, among other things, the frequency of your use of our Website, the pages visited, and the length of each visit.
• To display GVRR Capital advertisements when you visit websites of third parties with whom we have marketing relationships and to help us gauge the effectiveness of our advertising efforts. These parties may gather information concerning your use of other websites and provide us with de-identified information about you (such as demographic information or the names of sites where you have been shown ads) which we may use to provide you with more relevant and useful advertising.

Managing Cookies

The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the Web site of its manufacturer. Some of our sites employ “functionality cookies” that help the site remember your settings and preferences for use when you visit the site in the future. This provides a more tailored and pleasant user experience. These cookies store information in multiple places. On those sites using functionality cookies, you will find a “Delete Cookies” feature on every page that will allow you to delete these cookies completely from your device. Please note that, if you decline to use cookies, you may experience reduced functionality and, for sites using authentication-related cookies, declining cookies will prevent you from using the website altogether. To learn more about what cookies are set on your computer as you browse the Web and how to manage or delete them, visit allaboutcookies.org.