PRIVACY POLICY

Data Controller Contact Information:

Effective March 2022.

Email: info@tyr.capital

Phone:  +41 22 506 6072

TYR Capital Partners Sarl
Rue de Lausanne 15
1201 Geneva
Switzerland

This privacy policy applies to the information that we collect from you when you use our website www.tyr.capital, (the “Website”).

Our privacy policy tells you what personal data and nonpersonal data we may collect from you, how we collect them, how we protect them, how we share them, how you can access and change them, and how you can limit our sharing of them. Our privacy policy also explains certain legal rights that you have with respect to your personal data.

Definitions

‘NONPERSONAL DATA’ (NPD) is information that is in no way personally identifiable.

‘PERSONAL DATA’ (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data.

‘GDPR’ means General Data Protection Regulation.

YOUR RIGHTS

If you want to exercise any of your rights included in this privacy policy, contact us by using the information at the top of this privacy policy.

You Have the Right Not to Have Your Personal Information Sold

You have the right to request that we do not sell any of your personal information or share any of your information with third parties for behavioral advertising purposes.

If you wish to make this request, please email us at: info@tyr.capital telling us that you do not want to have any of your personal information sold or shared. Please include enough personal information so that we can reasonably verify your identification. We will respond to your request within 45 days after receiving it.

Your Rights Under the GDPR

When using our Website and submitting PD to us, you may have certain rights under the GDPR if

you reside or are in any of the countries of the European Union. If you reside in the United

Kingdom or EEA you may have the following additional rights under

the GDPR or applicable regulation:

  • The right to access (i.e., the right to be provided with a copy of your personal information);
  • The right to rectification (i.e., the right to require us to correct any mistakes in your personal information);
  • The right to be forgotten (i.e., the right to require us to delete your personal information – in certain situations);
  • The right to restriction of processing (i.e., the right to require us to restrict processing of your personal information – in certain circumstances, e.g., if you contest the accuracy of the data);
  • The right to data portability (i.e., the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations);
  • The right to object (e.g., the right to object to your personal information being used for direct marketing, and in certain other situations, the right to object to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests);
  • The right to withdraw consent (i.e., where processing is based on your consent, you have the right to withdraw that consent – without affecting the lawfulness of processing based on consent before its withdrawal);
  • The right to information regarding consent (i.e., to obtain information about the possibility or providing or denying your consent and the consequences of such consent or denial of consent); and/or
  • The right not to be subject to automated individual decision-making (i.e., the right not to be subjected to a decision based solely on automated processing – including profiling – that produces legal effects concerning you or similarly significantly affects you).

We will not discriminate against you if you choose to exercise any of these rights.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

Generally, you control the amount and type of information that you provide to us when using our Website.

Our Legal Basis for Collecting and Processing PD

Our legal basis for collecting and processing your PD when you buy our products or services is based on the necessity for the performance of a contract or to take steps to enter into a contract.

Automatic Information

We automatically receive information from your web browser or mobile device. This information may include the name of the website from which you entered our Website, if any, as well as the name of the website you’ll visit when you leave our Website. This information may also include the IP address of your computer/the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, and data about your browsing activity when using our Website. We use all this information to analyze trends among our users to help improve our Website.

When Entering and Using Our Website

When you enter and use our Website and agree to accept cookies, some of these cookies may contain your PD.

Our Use of Cookies

Our Website uses cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well.

By agreeing to accept our use of cookies you are giving us and the third parties with which we partner permission to place, store, and access some or all the cookies described below on your computer.

  • Strictly Necessary Cookies – These cookies are necessary for proper functioning of the Website, such as displaying content, logging in, validating your session, responding to your request for services, and other functions. Most web browsers can be set to disable the use of cookies. If you disable these cookies, you may not be able to access features on our Website correctly or at all.
  • Performance Cookies – These cookies collect information about the use of the Website, such as pages visited, traffic sources, users’ interests, content management, and other measurements.
  • Functional Cookies – These cookies enable the Website to remember users’ choices, such as their language, usernames, and other choices while using the Website.
  • Media Cookies – These cookies can be used to improve a Website’s performance and provide special features and content. They can be placed by us or third parties who provide services to us.
  • Advertising or Targeting Cookies – These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests. You will see less advertising if you disable these cookies.
  • Session Cookies – These cookies allow a website to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they browse a website. Session cookies also permit users to be recognized as they navigate a website so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; they are not stored long term.
  • Persistent Cookies – These cookies are stored on a user’s device between browser sessions, which allows the user’s preferences or actions across a website or across different websites to be remembered. Persistent cookies may be used for several purposes, including remembering users’ choices and preferences when using a website or to target advertising to them.
  • We may also use cookies for:
    • identifying the areas of our Website that you have visited
    • our Website analytics

Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access features on our Website correctly or at all.

Web Beacons

We may also use a technology called web beacons to collect general information about your use of our Website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers and users.

Collecting Information About Your Physical Location

When you use our Website, we may collect and process information about your actual physical location. We use several technologies such as IP tracking to determine your location. These technologies may also give us information about nearby cell towers, Wi-Fi access points, and other devices.

Google Analytics

Our Website uses Google Analytics to collect information about the use of our Website. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our Website, what pages they visit, and what other websites they have used before coming to our Website. We use the information we get from Google Analytics to analyze traffic, improve our marketing, advertising, and Website. Google Analytics collects only the IP address assigned to you on the date you visit our Website, not your name or other identifying information. We do not combine the information collected using Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you use our Website, the cookie cannot be used by anyone but Google. Google also uses specific identifiers to help collect information about the use of our Website.

  • For more information on how Google collects and processes your data visit: https://www.google.com/policies/privacy/partners/
  • You can prevent Google Analytics from using your information by opting out at this link: https://tools.google.com/dlpage/gaoptout

What Happens If You Don’t Give Us Your PD

If you do not provide us with enough PD, we may not be able to provide you all of our products and services. However, you can access and use some parts of our Website without giving us your PD.

HOW YOUR INFORMATION IS USED AND SHARED
We use the information we receive from you to:

  • provide our products and services you have requested or purchased from us
  • personalize and customize our content
  • make improvements to our Website
  • contact you with updates to our Website, products, and services
  • resolve problems and disputes
  • contact you with marketing and advertising that we believe may be of interest to you.

Communications and Emails

When we communicate with you, we will use the email address you provided when you registered as a user or customer. We may also send you emails with promotional information about our Website or offers from us or our affiliates unless you have opted out of receiving such information. You can change your contact preferences at any time through your account or by contacting us using the contact information at the top of this privacy policy.

Sharing Information with Affiliates and Other Third Parties

We do not sell or rent your PD to third parties for marketing purposes. However, for data aggregation purposes we may use your NPD, which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD. We may give your PD to service providers whom we hire to provide services to us. These service providers include web analytics companies, call centers, data management services, help desk providers, accountants, law firms, auditors, email service providers, and shipping companies.

Legally Required Releases of Information

We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or governmental enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our terms and conditions; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.

Disclosures to Successors

If our business is sold or merges in whole or in part with another business that would become responsible for providing our Website to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy policy. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.

 

RETAINING AND DESTROYING YOUR PD
We retain information that we collect from you (including your PD) only for as long as we need it for legal, business, or tax purposes. Your information may be retained in electronic, paper, or a combination of both forms. When your information is no longer needed, we will destroy, delete, or erase it.

UPDATING YOUR PD
You can update your PD using services found on our Website. If no such services exist, you can contact us using the contact information found at the top of this privacy policy and we will help you. However, we may keep your PD as needed to enforce our agreements and to comply with any legal obligations.

DO NOT TRACK SETTINGS

Some web browsers have settings that enable you to request that we do not track your movement within our Website. Our Website does not obey such settings when transmitted to and detected by our Website. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.

LINKS TO OTHER WEBSITES

Our Website may contain links to other websites. These websites are not under our control and are not subject to our privacy policy. These websites will likely have their own privacy policies. We have no responsibility for these websites and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy policies of these websites to see how they treat your PD.

PROTECTING CHILDREN’S PRIVACY

Even though our Website is not designed for use by anyone under the age of 16, we realize that a child under the age of 16 may attempt to access our Website. We do not knowingly collect PD from children under the age of 16. If you are a parent or guardian and believe that your child is using our Website, please contact us. Before we remove any information we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child is accessing our Website, we will delete his/her information within a reasonable period of time. You acknowledge that we do not verify the age of our users nor have any liability to do so.

OUR EMAIL POLICY
You can always opt out of receiving email correspondence from us or our affiliates by using the link within the email. 

OUR SECURITY POLICY
We have built our Website using industry-standard security measures and authentication tools to protect the security of your PD. We and our service providers also maintain technical and physical safeguards to protect your PD. Unfortunately, we cannot guarantee prevention of loss or misuse of your PD or secure data transmission over the Internet because of its nature. We strongly urge you to protect any password you may have for our Website and not share it with anyone.

TRANSFERRING PD FROM THE EUROPEAN UNION

PD that we collect from you may be stored, processed, and transferred among any countries in which we operate. If you are a European Union customer or user, with your consent your PD may be transferred to the United States or other countries outside the European Union when you request information from us. When you buy goods or services from us, we will use your PD for the performance of a contract or to take steps to enter into a contract. Wherever we transfer, process, or store your PD, we will take reasonable steps to protect it. We will use the information we collect from you in accordance with our privacy policy. By using our Website, services, or products you agree to the transfers of your PD described within this section.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this privacy policy at any time. If our company decides to change this privacy policy, we will post those changes on our Website so that our users and customers are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email sent to the email address on file in your account. Otherwise we will use and disclose our users’ and customers’ PD in agreement with the privacy policy in effect when the information was collected. In all cases your continued use of our Website, services, and products after any change to this privacy policy will constitute your acceptance of such change. If you have questions about our privacy policy, please contact us through the information at the top of this privacy policy.

Effective March 2022.

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