INTRODUCTION
At CoInvestments.ai, we are committed to protecting the privacy and security of your personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your data in compliance with the Financial Industry Regulatory Authority (FINRA), the U.S. Securities and Exchange Commission (SEC) regulations, including Regulation S-P, the General Data Protection Regulation (GDPR), and other applicable laws. This policy applies to all users of our website, services, and platforms (collectively, “Services”).
INFORMATION WE COLLECT
We collect information to provide our executive search services and to comply with regulatory obligations. The types of personal information we may collect include:
*Personal Identifiers: Name, email address, phone number, mailing address, and other contact details.
*Professional Information: Employment history, qualifications, skills, and other profile-related data provided by candidates or hiring firms.
*Technical Data: IP address, browser type, device information, and website usage data collected automatically through cookies and similar technologies.
*Sensitive Information: Where required for regulatory or service purposes, we may collect government-issued identification numbers or other sensitive data, subject to strict safeguards.
HOW WE COLLECT INFORMATION
*Directly from You: When you submit profiles, contact us, or engage with our Services.
*Automatically: Through cookies, analytics tools, and other technologies as you interact with our website.
*From Third Parties: From business partners, regulatory bodies, or other authorized sources, where permitted.
HOW WE USE YOUR INFORMATION
We use your information to deliver our executive search services and to meet regulatory requirements, including:
*Facilitating curated introductions between candidates and hiring firms.
*Personalizing and improving the usability of our Services.
*Complying with FINRA and SEC requirements, such as record-keeping under SEC Rules 17a-3 and 17a-4.
*Preventing, detecting, and investigating fraud or unauthorized activities.
*Responding to your inquiries and providing customer support.
For GDPR compliance, processing is based on lawful grounds such as your consent, contractual necessity, or our legitimate interests in providing secure and effective services.
HOW WE SHARE YOUR INFORMATION
We do not sell your personal information. We may share your data under the following circumstances:
*With Your Consent: For specific purposes, such as connecting candidates with hiring firms.
*Service Providers: With trusted vendors (e.g., cloud hosting, analytics) who are contractually obligated to protect your data.
*Regulatory Compliance: With FINRA, SEC, or other authorities as required by law, including for audits or investigations.
*Legal Obligations: To comply with legal processes, such as subpoenas, or to protect our rights and safety.
DATA PRIVACY AND PROTECTION
We implement commercially reasonable technical, administrative, and physical security measures to protect your information, in line with SEC Regulation S-P and GDPR requirements. These include:
*Encryption: Using SSL/TLS encryption for data transmission.
*Access Controls: Restricting access to authorized personnel only.
*Data Minimization: Collecting only what is necessary for our services.
*GDPR Rights: For EU residents, you have the right to access, rectify, erase, restrict, or object to the processing of your data, as well as data portability. Contact us at [insert contact email] to exercise these rights.
COOKIES AND TRACKING TECHNOLOGIES
Our website uses cookies and similar technologies to enhance user experience and analyze usage. You can manage cookie preferences through your browser settings. For details, see our Cookie Policy [link to Cookie Policy, if applicable].
DATA RETENTION
We retain personal information for as long as necessary to fulfill the purposes outlined in this policy or as required by law (e.g., SEC Rules 17a-3 and 17a-4 require retention of certain records for at least six years). When no longer needed, data is securely deleted or anonymized.
INTERNATIONAL DATA TRANSFERS
For GDPR compliance, if we transfer EU residents’ data outside the European Economic Area (EEA), we ensure appropriate safeguards, such as Standard Contractual Clauses, to protect your information.
THIRD-PARTY LINKS
Our Services may contain links to third-party websites. We are not responsible for the privacy practices or content of these sites. Please review their privacy policies before sharing information.
UPDATES TO THIS POLICY
We may update this policy to reflect changes in our practices or legal requirements. We will notify you of significant changes via our website or by email. The updated policy will be effective upon posting.
CONTACT US
If you have questions, concerns, or wish to exercise your GDPR rights, please contact us at:
CoInvestments.ai
Email: Privacy@coInvestments.ai
For complaints, EU residents may also contact their local data protection authority.
Last Updated: January 1, 2020
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