We, the team of The Secret Capital (hereinafter — the "Company," "we," "us"), welcome you to our Website and appreciate your interest in our services.
We understand that the confidential storage of your data and your privacy are important to you. This page explains how we process your personal data (Privacy Policy).
By continuing to use our Website, you confirm that you are 18 years of age or older. We may amend this Policy from time to time. The applicable version is always the current version posted on this page. If we decide to change our Privacy Policy, we will post the changes on this page. Please check this page periodically to ensure you are aware of the latest changes.
This Policy applies to any and all data collected by us in connection with your use of this Website. Please read this Privacy Policy carefully and ensure that it is fully clear to you. Your consent to the Privacy Policy is deemed confirmed upon your first use of our Website. If you do not accept and agree to this Privacy Policy, you must immediately stop using this Website.
Depending on your location and citizenship, we comply with the following regulations. For the European Union: as of May 25, 2018, the EU General Data Protection Regulation 2016/679 (GDPR) came into force. We ensure the processing of your personal data in accordance with this Regulation. For the Russian Federation: if you are a resident or citizen of the Russian Federation, we process your personal data in accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data." Consent to processing is requested separately, in advance, provided via your email address. Data is stored no longer than required by the purposes of processing. You have the right to access, rectify, and delete your data. For CIS countries: for citizens and residents of CIS countries, the provisions of national personal data legislation of the respective countries apply (Republic of Kazakhstan, Republic of Belarus, Republic of Uzbekistan, and others).
Our role includes the obligation to ensure conditions under which your data and data of any third parties (such as employees, contractors, clients, executives, and other persons related to you and counterparties) that have come or may come into our possession and which may also contain confidential information, are processed in accordance with this Regulation and/or other applicable laws.
- Contact information (last name, first name, email address, phone number);
- Due diligence data (information to confirm qualified investor status);
- Technical data (IP address, browser type, operating system, country of residence);
- Usage data (referral URLs, activity on the Website).
- Providing and managing your access to this Website;
- Responding to your inquiries via contact forms;
- Conducting due diligence and verifying qualified investor status;
- Sending informational and investment materials upon your request;
- Analyzing Website usage to improve user experience. We also reserve the right to request information necessary to comply with the requirements of our counterparties (exchanges, custodians, banks), including minimum source-of-funds checks as part of standard practice in digital assets. We do not send marketing communications without your separate consent. You may opt out of receiving any materials at any time;
- Facilitating the technical administration of this Website.
- Your consent (Article 6(1)(a) of the GDPR) – for processing data you voluntarily provide in feedback forms on the Website (last name, first name, email, phone), as well as for collecting technical data (cookies, analytics) and improving user experience. Consent is given by checking a separate checkbox;
- Performance of a contract (investment agreement) (Article 6(1)(b) of the GDPR) – for processing data necessary for due diligence, verifying qualified investor status, transferring data to counterparties for the execution of investment strategies, and for sending requested investment materials;
- Compliance with legal obligations – in cases where processing is required by a request from state authorities in accordance with the law.
We take all necessary technical and organizational security measures to protect your personal data from unauthorized access, misuse, loss, and/or destruction.
Our employees and contracted service providers are required to maintain professional secrecy and comply with all data protection regulations.
Furthermore, access to personal data is only available to those employees, contractors, and third parties who need it to perform their duties.
We take the following steps to ensure the security and protection of your data:
- We use strong, 2048-bit SSL certificate encryption;
- We use Alphabet's (Google) email services, which feature a high degree of security;
- We follow strict internal procedures when handling any confidential data.
Our Website may use cookies to enhance your user experience. Cookies are small pieces of information that are sent to your browser and stored on your computer's hard drive. We use analytical cookies (Google Analytics, Yandex Metrica) to collect visit statistics, as well as technical cookies for the proper functioning of the Website. Most browsers automatically accept cookies. You can change your browser settings to disable them. If you do not agree to the use of cookies, please leave the Website.
- Request information about your personal data that we hold;
- Request the deletion of your data if we are not entitled or required by law to retain it;
- Request that the processing of your data be restricted;
- Object to the processing of data by us;
- Withdraw your consent to data processing at any time;
- Request the transfer of your data to you in a commonly used, machine-readable, and standardized format.
You also have the right to lodge an appeal (to the extent it concerns you) with the relevant supervisory authority for data protection.
As a data subject, you can contact the company's employee responsible for this area with any issue concerning your data protection rights.
To exercise your rights, please send a request to support@thesecretcapital.com with the subject line "Personal Data." We undertake to respond to your request within 30 days.
- To counterparties (exchanges, custodians, auditors, liquidity providers) solely for the purpose of executing investment strategies and subject to a confidentiality agreement;
- To legal advisors for compliance purposes;
- o state authorities in accordance with the law. In cases where it is required to access the services of our counterparties, we may provide them with the minimum necessary set of data to pass their internal verification procedures.
We may also collect anonymized statistics about Website usage. Such data does not contain personally identifiable information.
Your personal data may be transferred to the territory of foreign countries (including countries outside the EU) in cases related to the execution of digital asset transactions through international cryptocurrency exchanges and DeFi protocols, as well as when using cloud storage services. When carrying out cross-border transfers, we take measures to ensure the protection of your rights.
