Privacy policy
Scope of the Privacy Policy
Constructor Capital (“Constructor Capital”, “we”, “us”) is a global investment fund that operates the website constructor.capital (the “Website”).
This policy explains how personal data is handled when you visit the Website or contact us through it.
We process personal data in accordance with the applicable data protection laws, in particular and where applicable the General Data Protection Regulation (EU) 2016/679 (GDPR), the Swiss Federal Act on Data Protection and the UK GDPR.
We process personal data only if provided directly by you and strictly to the extent necessary to answer your requests, or as necessary for the basic technical operation of the Website.
Personal data means any information relating to an identified or identifiable person, for example a name, an e-mail address or, in combination with other data, an IP address.
The Website is not directed at children, and we do not knowingly collect personal data of persons under 18.
Description of collected personal data and legal basis for collecting personal data
Visiting the Website
When you open the Website, our hosting provider automatically records technical data that your browser sends: IP address, date and time of the request, the page requested, the referring page, browser type and version, operating system and device type. These server logs are needed to deliver the pages, keep the Website secure and diagnose faults. They are not combined with other data about you and are retained only for as long as necessary for these purposes.
Cookies
The Website sets two kinds of cookies, described in the Cookies section below: necessary cookies, which the Website needs to work, to remember your cookie choice and to protect the contact form from spam, and which do not require your consent; and analytics cookies (Google Analytics), which we set only after you have accepted them in the cookie banner.
Contacting us
If you choose to contact us through the contact form or by e-mail, we process only the personal data you voluntarily provide—typically your name, e-mail address, company and the content of your message—strictly to the extent necessary to answer your request. Form submissions are received and stored by our hosting provider Webflow and forwarded to us by e-mail / into a spreadsheet; they are retained only for as long as necessary to handle your request. If you send us personal data of other people (for example a co-founder’s contact details), you must ensure that you are allowed to do so and you remain liable for such data towards third parties.
Investor Portal
The Investor Portal linked from the Website is operated independently by a third party ([Intralinks]) under its own terms and privacy policy. We do not process your login or usage data of that portal through the Website, and we assume no liability or responsibility for its operation, content, or data processing practices. If you submit information to this site, your information is governed by the privacy policies that apply to the site. We encourage you to carefully read the privacy policy of any website or application you visit.
We process personal data on the following legal basis:
- your consent, which you can withdraw at any time via “Cookie settings” in the footer or by sending us an email;
- the performance of a contract or steps before entering into one
- our legitimate interests to operate and secure the Website,
- compliance with legal obligations.
- We do not take decisions about you based solely on automated processing, and we do not sell personal data.
Cookies
A cookie is a small text file that the Website stores on your device. The Website uses the following cookies:
- cc_consent - set by constructor.capital, necessary. Remembers your cookie choice so you are not asked again on every visit.
- _ga - set by Google Analytics, analytics Distinguishes visitors for the usage statistics. Set only after consent.
- _ga_* - set by Google Analytics, analytics. Keeps the Google Analytics session state for this website’s property. Set only after consent.
- _cfuvid - set by Cloudflare, necessary, session (deleted when you close the browser). Protects the contact form from spam (Cloudflare Turnstile) by telling apart visitors who share one network.
Google Analytics 4 is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. It helps us understand how the Website is used (number of visits, traffic sources, pages viewed). IP addresses are anonymised, and nothing is sent to Google before you accept analytics cookies. Google may transfer data to Google LLC in the United States; such transfers rely on the Swiss–US and EU–US Data Privacy Framework and the standard contractual clauses. Google’s privacy policy: policies.google.com/privacy.
Some articles embed videos from YouTube in privacy-enhanced mode (youtube-nocookie.com). YouTube sets no cookies on your device until you start a video; once you do, Google’s privacy policy applies to the data YouTube processes.
You choose which cookies may be set in the banner shown on your first visit. You can change or withdraw your choice at any time via Cookie settings (also in the footer of every page); withdrawing analytics consent deletes the Google Analytics cookies from your browser. You can also block or delete cookies in your browser settings; the Website keeps working without analytics cookies.
Data Retention
We retain personal data only for as long as necessary to fulfill the processing purposes for which it was collected (such as responding to your inquiry or ensuring website functionality) or as required to comply with statutory legal and regulatory obligations. Once no longer required, personal data is securely deleted or anonymized.
Data Transfers
Your personal data may be transferred to, and processed in, countries other than the country in which you are based, where our affiliates, subsidiaries, partners or our third-party service providers operate.
Some of these countries might not be considered as adequate by the European Commission and therefore not offer an adequate level of protection and security. As a result, we take measures to ensure that your information is safe and protected in compliance with the applicable data protection laws, including:
- reliance of Standard Contractual Clauses to transfer your data outside the European Economic Area, United Kingdom and Switzerland;
- implementation of organizational, contractual and technical security measures with our third-party service providers;
- establishment of an intra-group data transfer agreement for internal transfers of personal data within our group of companies around the world.
Third Party websites
The Website may contain links to third-party websites and platforms (such as LinkedIn, YouTube, Spotify, Google, and the Investor Portal). These links are provided solely for convenience. Third-party operators process data under their own independent privacy policies and terms. We do not control, supervise, endorse, or accept any liability or responsibility whatsoever for the content, privacy policies, or data processing activities of any third-party websites or services. Accessing external links is entirely at your own risk.
Your Privacy rights
You may make certain choices regarding your personal data as permitted under applicable privacy laws. You may make these choices free of charge except as otherwise permitted under applicable law. We may ask you to further confirm your identity and limit our response to your requests as permitted under applicable law.
Your privacy rights include:
- Right to be Informed: You have the right to be informed about the collection and use of your personal data. This includes your right to request a copy of the standard contractual clauses including completed and signed annexes and excluding any confidential information, business secrets, and personal data of third parties in case we process your personal data relying on such terms and conditions with other data processors.
- Right to Access: You have the right to view and request copies of your personal data. If you have an online account or profile with us, you may access your personal data via your account through the website or mobile app.
- Right to Rectify or Correct: You have the right to update the personal data that we have collected about your directly or indirectly, including personal data collected by a service provider or contractor on our behalf. If you have an online account or profile with us, you may update your personal data by accessing your account through the website and mobile app.
- Right to Request Erasure (Right to be Forgotten): You may request that we delete your personal data, subject to certain limited exceptions. For example, we may retain an archived copy of your records consistent with applicable law, to comply with legal obligations, or for other legitimate business purposes. Before processing a personal data deletion request, we might conduct a legitimacy assessment to verify the identity and authority of the requester. This is to ensure that the person making the request is authorized to do so and to prevent unauthorized access or deletion of personal data. We may request additional information or documentation to confirm your identity. We will use commercially reasonable efforts to honour your requests.
- Right to Data Portability: You have the right to request that we transfer data that we have collected to another organization, or directly to you under certain conditions.
- Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data under certain conditions.
- Right to Withdraw Consent: You have the right to withdraw previously granted consent to process your personal data.
- Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions.
- Right to Object to Automated Processing: You have the right to object to decisions being made with your information solely based on automated decision making or profiling. we do not currently engage in automated decision-making or profiling.
To exercise any of your above rights you may submit your request at privacy@constructor.org
If you believe that we process your data in breach of the law, you can contact us at the e-mail address above. You also have the right to lodge a complaint with the supervisory authority of your country of residence, place of work or the place of the alleged breach.
Data Security
The security of your personal information is important to us.
We follow generally accepted security standards and we have adopted commercially reasonable security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access including encrypted connections (TLS), access controls and contractual obligations on our service providers. We may use third-party products and services to secure or store your information.
Depending on where you live, you may have a legal right to be notified in case of security breach.
However, please note that transmissions over the internet cannot be guaranteed to be completely secure. To the maximum extent permitted by applicable law, we disclaim any liability for security incidents or data breaches arising from factors beyond our reasonable control.
Changes to this Policy
We reserve the right to amend this Policy at our discretion and at any time. We will do so by updating this Policy. Amended terms take effect upon being incorporated into this Policy, and your continued use of the website or association with your employer following the posting of any changes constitutes acceptance of any updated terms. If the changes will materially affect the way we use your personal data in connection with services that we have already collected, we will notify you or your employer. You can always find the latest version of this Policy on our website.
Contact
Constructor Capital