Privacy Policy

Effective date: 2nd December, 2024

1. Introduction

1PLTFRM Technology, LLC and 1PLTFRM Services, LLC (collectively, “1PLTFRM”, “Company,” “we,” “us,” or “our”) are responsible for the operation, management, and support of the 1PLTFRM domain (1pltfrm.com) and subdomains (i.e., vitrina.1pltfrm.com) and are committed to protecting the privacy of individuals (“Users”) who access or use our  website and services (collectively, the “Services”). 1PLTFRM may process your Personal Data in accordance with this Privacy Policy. The Services encompass the following:

1. 1PLTFRM Vitrina:  A secure, invitation-based digital platform operated by 1PLTFRM. Vitrina Showcase enables general partners and issuers to showcase their alternative investment offerings to selected financial intermediaries and professional investors. It is designed to enhance private wealth distribution by providing tools for targeted intermediary engagement, streamlined onboarding, and efficient investment servicing. Vitrina Invest then enables those financial intermediaries and professional investors to indicate their interest in a particular offering, and manage the full onboarding, subscription, capital management and reporting process.

2. Public website: Which serves as a marketing and informational platform designed to provide general users with an overview of our services, features, and value propositions.

This Privacy Policy describes how we collect, use, disclose, and safeguard your Personal Data when you use our Services.

This Privacy Policy applies to all Users, including:

  • Issuer Users: Employees, representatives, or agents of our Customers (Issuers with a commercial agreement with us) who have registered with Vitrina.
  • Invited Users: Individuals granted access to Vitrina by an Issuer User and who have registered with Vitrina in order to view one or more offerings from such Customer.
  • Advisor Users: Individuals granted access to Vitrina by an Issuer User and who have registered with Vitrina. These Users typically are employed by a Wealth Manager.
  • Investors: Individuals granted access to Vitrina by an Advisor User and who have registered with Vitrina. These Users typically have a relationship with a Wealth Manager, and may use the Services to undertake a transaction (a subscription for an alternative investment made available by an Issuer).
  • Visitors: Individuals accessing publicly available content on our website without registering.

By accessing or using the Services, you agree to the collection and use of your information in accordance with this Privacy Policy.

2. Definitions

  • “Issuer” means a firm responsible for managing or issuing investments listed on the 1PLTFRM platform, including but not limited to general partners, investment managers, and sponsors. This entity oversees the fund or investment offering and interacts with Wealth Managers and potential investors through the platform. 
  • “Wealth Manager” means a firm which advises clients on building and managing their portfolios, recommending investment opportunities to align with the client’s financial goals, risk tolerance, and overall strategy.
  • “Personal Data” means any information relating to an identified or identifiable individual.
  • “KYC Information” refers to information collected for Know Your Customer and Anti-Money Laundering (AML) purposes, including identity verification and financial information.

3. Information We Collect

3.1. Information Provided by Users

a. Account Information During and Subsequent to Registration

  • Contact Details: Such as name, email address, phone number, job title, company name.
  • Authentication Data: Such as user name, password, and other credentials necessary to access the Services.
  • KYC Information: Such as financial and employment information, identity documents (e.g., passports, driver’s licenses), proof of address, and other documentation required for identity verification and AML compliance.

b. Communications

  • Information you provide when you contact us via public website form, email, phone, or through our customer support platform.

c. Transaction Information

  • Records of transactions and interactions within the Services.

3.2. Information Collected Automatically

  • Usage Data: Details of your use of the Services, including pages viewed, features used, and timestamps.
  • Device Information: IP address, browser type and version, operating system, device identifiers.
  • Cookies and Similar Technologies: We use cookies, web beacons, and other tracking technologies to collect information about your interaction with the Services.

3.3. Information from Third Parties

  • Customer-Provided Data: Information about Users provided by Customers in order to provide us with the means to enable them to register on the platform.

4. How We Use Your Information

We may use the information we collect for various purposes, including:

  • To Provide and Maintain the Services:
    • Facilitate account creation and authentication.
    • Process and report on transactions and execute requests.
    • Verify identities and conduct due diligence for KYC and AML compliance.
  • To Improve the Services:
    • Analyze usage patterns to enhance functionality and user experience.
    • Develop new features and services.
  • To Communicate with You:
    • Send administrative information, such as account notices and updates.
    • Respond to inquiries, support requests, and feedback.
  • For Marketing Purposes:
    • Send promotional materials, newsletters, and other information that may be of interest to you, where permitted by law and with your consent if required.
  • To Enforce Our Terms and Policies:
    • Ensure compliance with our Terms of Services and other legal agreements.
    • Detect, prevent, and address fraud, security, or technical issues.
  • To Comply with Legal Obligations:
    • Fulfill legal, regulatory, and compliance requirements, including those related to KYC and AML laws.
    • Respond to subpoenas, court orders, or legal processes.

5. Who Within 1PLTFRM Has Access To Your Information

  • Only a very limited set of authorized individuals may access your Personal Data, on a strict need-to-know basis which is enforced through fully auditable roles-based system access. 
  • All individuals are informed of the personal nature of this data, have received appropriate training regarding its processing and protection and have committed to strict confidentiality terms. 

6. How We Share Your Information

6.1. With Customers

  • We may share your Personal Data with the respective Customer for account management, compliance, and auditing purposes.

6.2. With Service Providers

  • We may disclose your information to third-party service providers who perform services on our behalf, such as:
    • Data Storage and Hosting Providers: To securely store and manage data.
    • Digital Signature Providers: To enable electronic approvals for transactions.
    • Analytics Providers: To analyze Services usage and improve performance.

6.3. With Fund Administrators

  • We may share your Personal Data with fund administrators who are contracted to process fund subscriptions and manage investment transactions on behalf of our Customers. These administrators are authorized to use your information solely for the purpose of providing these services and are obligated to protect your data in accordance with applicable laws.

6.4. Legal Requirements

  • We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

6.5. Business Transfers

  • In the event of a merger, acquisition, restructuring, or sale of all or a portion of our assets, your Personal Data may be transferred to the acquiring entity.

6.6. With Consent

  • We may share your information with third parties when you have provided explicit consent.

7. Our Role as a Data Processor

  • 1PLTFRM acts as a data processor, meaning we process Personal Data on behalf of organizations, such as Issuers and Wealth Managers, who act as the data controllers. The processing of such data is governed by Data Processing Agreements (DPAs) between 1PLTFRM and the data controllers. These agreements ensure that all data is handled in compliance with applicable data protection laws, including GDPR and similar frameworks.
  • If you have questions about how your Personal Data is processed or wish to exercise your data protection rights, please contact your Wealth Manager directly as the data controller.

8. International Data Transfers

  • Your Personal Data is stored in Switzerland.
  • We may transfer your Personal Data to countries other than Switzerland for processing. When we transfer data, we ensure that the same level of data protection and security is maintained as in Switzerland. 
  • If you are located outside the USA and choose to provide information to us, please note that we may transfer the data, including Personal Data, to the USA and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. 
  • 1PLTRFM complies with the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  1PLTFRM has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit the Data privacy framework website.

9. Data Security

  • We implement appropriate technical and organizational measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction.
  • Security Measures Include:
    • Leveraging end-to-end encryption and adhering to zero trust security guiding principles
    • Encryption of data in transit and at rest.
    • Access controls and authentication protocols.
    • Automated threat detection and continuous monitoring.
    • Regular security assessments and audits.
  • No Absolute Guarantee: While we strive to protect your information, we cannot guarantee its absolute security.

10. Data Retention

  • Retention Periods: We retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
  • Criteria for Retention:
    • Duration of your contractual relationship with us.
    • Legal obligations to retain data (e.g., for tax, accounting, or regulatory purposes).
    • Resolution of disputes and enforcement of agreements.
  • Deletion Requests: You may request the deletion of your Personal Data by contacting us at support@1pltfrm.com. We will comply with your request where required by law.

11. Cookies and Similar Technologies

  • Use of Cookies: We use cookies and similar technologies to enhance your experience, analyze usage, and deliver personalized content.
  • Types of Cookies:
    • Session Cookies. We use Session Cookies to operate our Services.
    • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
    • Security Cookies. We use Security Cookies for security purposes.
    • Managing Cookies: You can manage or disable cookies through your browser settings. However, disabling cookies may affect the functionality of the Services.

12. Your Rights and Choices

12.1. Access and Correction

  • You have the right to access the Personal Data we hold about you and to request corrections of any inaccuracies.

12.2. Opt-Out of Marketing Communications

  • You may opt out of receiving promotional emails by following the unsubscribe instructions included in such emails or by contacting us at support@1pltfrm.com.

12.3. Do Not Track Signals

  • Our Services do not respond to Do Not Track (DNT) signals. You can set your browser to refuse certain cookies or to alert you when cookies are being sent.

12.4. General Data Protection Regulation

1PLTFRM complies with Swiss data protection laws (Federal Act on Data Protection (FADP)). These align closely with the EU General Data Protection Regulation (GDPR), which gives you certain rights, including:

  • Right to Access: Obtain confirmation as to whether your Personal Data is being processed.
  • Right to Rectification: Request correction of inaccurate or incomplete data.
  • Right to Erasure: Request deletion of your Personal Data under certain conditions.
  • Right to Restrict Processing: Limit the processing of your data under specific circumstances.
  • Right to Data Portability: Receive your Personal Data in a structured, commonly used format.
  • Right to Object: Object to the processing of your data for direct marketing purposes or on grounds relating to your particular situation.
  • Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.

To exercise these rights, please contact us at support@1pltfrm.com.

13. Children’s Privacy

  • Our Services are not intended for individuals under the age of 18. We do not knowingly collect Personal Data from children under 18.

14. Third-Party Links

  • The Services may contain links to third-party websites or services not operated by us.
  • No Responsibility: We are not responsible for the content, privacy policies, or practices of any third-party sites or services. We encourage you to review their privacy policies.

15. Changes to This Privacy Policy

  • We may update this Privacy Policy from time to time.
  • Notification of Changes: We will notify you of any significant changes by posting the new Privacy Policy on this page and updating the “Effective Date” at the top.
  • Continued Use: Your continued use of the Services after any changes signifies your acceptance of the updated Privacy Policy.

16. Contact Information

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:

  • Email: support@1pltfrm.com

17. Legal Bases for Processing

We process your Personal Data based on the following legal grounds:

  • Consent: Where you have given explicit consent for specific purposes.
  • Contractual Necessity: Processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
  • Legal Obligation: Compliance with a legal obligation to which we are subject, including KYC and AML regulations.
  • Legitimate Interests: Processing is necessary for our legitimate interests, such as improving our Services, provided that such interests are not overridden by your rights and interests.

18. Data Breach Notification

  • In the event of a data breach that affects your Personal Data, we will notify you and the appropriate regulatory authorities within the timeframes required by applicable law.

19. Supervisory Authority Contact

  • If you believe that our processing of your Personal Data infringes data protection laws, you have the right to lodge a complaint with a supervisory authority. 
  • In the first instance please refer to the Swiss Federal Data Protection and Information Commissioner (FDPIC) as an independent dispute resolution body. 

20. Additional Disclosures

  • Data Anonymization: We may anonymize or aggregate your data for analytical purposes, in which case it will no longer be considered Personal Data.
  • Automated Decision-Making: We do not use automated decision-making processes that have a legal or significant impact on you.