Vis Caeli Privacy Notice
Vis Caeli collects personal data about you from your use of this website. We are a controller under the General Data Protection Regulation (“GDPR”) and process Personal Data provided by you through your use of our website. This Privacy Notice explains how we collect Personal Data obtained from you through your use of our website.

Disclaimer
The materials on Vis Caeli website are provided on an ‘as is’ basis. Vis Caeli makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties including, without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights.
The content on our website is provided for general information only. It is not intended to amount to advice.
Further, Vis Caeli does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its website or otherwise relating to such materials or on any sites linked to this site.

Limitations
In no event shall Vis Caeli or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the materials on Vis Caeli website, even if Vis Caeli authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.

1. What Personal Data do we collect?
Personal Data is any information relating to you or that we can otherwise link to you. The Personal Data we collect on this website may include your name, email address, address and other contact information.
We may also collect information about your use of the website when you enter and browse the website through the use of “cookies,” web server logs and other electronic tools. This information may include, without limitation, the number and frequency of your visits to the website, the websites accessed before and after you visit the website, the internet browsers used by you and your IP addresses.
For data processing subject to GDPR, the legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.

2. How do we collect Personal Data?
We collect Personal Data that you voluntarily provide to us, such as through forms you choose to submit to contact us to obtain more information about Vis Caeli.
We may also collect Personal Data through the use of a cookie on our website.
This Privacy Notice does not address our privacy practices with respect to any Personal Data we may collect from an investor in funds that we sponsor or manage. We address these practices in separate notices to investors as required by law.

3. How do we use your Personal Data?
We use the information we collect to:
  • Deliver and improve the Services and your overall user experience.
  • To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • To link or combine user information with other Personal Information.
  • To compare and verify information for accuracy and update our records.
  • Email, text, message, or otherwise contact you with information and updates about us and the Services
  • To respond to your comments and questions and provide customer service.
  • To send you information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
  • Analyze how you use the Services with tools such as Google Analytics and other tools to help us understand traffic patterns and know if there are problems with the Services.
  • Create targeted advertising to promote the Services and engage our users.

4. Why do we process your Personal Data?
We process your Personal Data for communication and marketing purposes.

5. What legal basis do we use to process your Personal Data?
We rely on our legitimate business interests in maintaining business relationships and communicating about Vis Caeli business.

6. Is it necessary to provide Personal Data?
You are not required to submit information to us through this website. However, we may collect cookies, which do not require your consent.

7. With whom do we share your Personal Data?
We do not rent, sell, or share your Personal Information with other people or non-affiliated third parties except with your consent or as necessary to complete any transaction or provide any service you have requested or authorized.
To help us do our work, we may provide limited access to some of your Personal Information to the following third parties:
  • Partners: Sometimes we collaborate with other organizations to deliver the Services. In these cases, we may share your name, contact information and other details you provided when making an account with our partners.
  • Affiliates: We may share your information with our affiliates and/or subsidiaries.
  • Service Providers: We work with a wide range of third party providers, notably our database administrators, cloud computing services, advertising services, data analysts, application service providers, bulk SMS services, and other non-governmental organizations.
  • Payment processors:  We work with payment processors such as Stripe to help process credit card transactions and other payment methods made through the Services. These payment processors will store certain information about you. Please refer to their privacy policies to learn more about how they use your Personal Information.
  • Other Users: We may share redacted information of our users with other users of our Services for the purpose of getting your consent to make introductions for relevant opportunities.
We may store information, using our internal tools, such as your contact information and employment details, that are necessary to enable us to operate effectively and deliver our services to you. We may also transfer your Personal Information to a third party as a result of a merger, acquisition, reorganization or similar transaction; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Services; and to protect the rights or property of Company. In such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Information, give you an opportunity to consent to such changes.

8. How long do we retain your Personal Data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Your Personal Data will be retained for as long as you are a business contact to us, or longer as required by applicable law.
Your Personal Data may be deleted when it is no longer relevant or when you withdraw consent (see below), again within the parameters of applicable law.
You may unsubscribe at any time from communications from us, and we will cease sending you further communications.

9. What are my rights with respect to my personal data?
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


10. What security do we have in place over your personal data?
Vis Caeli has implemented appropriate technical security measures to help protect your Personal Data against loss and to safeguard your Personal Data against access by unauthorized persons. We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your Personal Data obtained through use on this website.

11. What are our procedures in the event of a breach to your Personal Data?
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data, we will notify the applicable supervisory authority in the European Union within 72 hours of discovering the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons. We will also notify each affected subject of a breach without undue delay if the breach is likely to result in a high risk to the rights and freedoms of natural persons. We are not required to notify you of a breach if the breached data is encrypted, if we have taken measures, such as wiping the data remotely, and such breach is unlikely to result in a material adverse effect, or if providing notice requires disproportionate efforts, in which case a public communication should be made, rather than notice to each person.

12. Updates to this privacy statement
This Privacy Notice was updated in February 2022. We may amend this notice from time to time to reflect changes in our practices with respect to the processing of Personal Data or changes in applicable law.

13. Contact information
If you have any questions about how we process your Personal Data, please contact us at community@viscaeli.com