GDPR Privacy Policy

Last Updated: September 30, 2022

Lionheart Strategic Management, LLC (hereinafter “COMPANY”, “we”, “us” and “our”) values your privacy. This GDPR Privacy Notice (“Privacy Notice”) applies to information we collect from or about investors and visitors to our websites or investor portal, and to users of the services we provide (the “Services”). The purpose of this Privacy Notice is to provide you with information concerning how we collect, use, maintain, and share your personal information in accordance with applicable data protection laws.

NOTE: This GDPR Privacy Notice does not apply to you if you reside outside of the European Economic Area (“EEA”), United Kingdom, or Switzerland. If you reside in any of those jurisdictions, you are subject to our GLBA Privacy Notice.

Personal information is processed by or on behalf of the controller:

Lionheart Strategic Management, LLC
Attn: Legal Department
605 Third Avenue, 36th Floor
New York, NY 10158

Information We Collect and Process

We may collect one or more of the following categories of personal information about our investors, potential investors and visitors to our websites or investor portals when these individuals (i) visit those sites; (ii) request additional information about our Services; (iii) invest through us or otherwise use our Services; or (iv) otherwise interact with us.

    

    Category of Personal Information (PI) collected
        Sources of PI
        Purposes of collecting PI
        Categories of third parties to whom we disclose PI
    

    
        Identifiers such as full name, date of birth, nationality, gender, email address, phone number or postal address.
        Information you provide us; information collected from third parties; information we may receive from third-party marketing and data partners.
        To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; engage in marketing activities; internal research and development.
        Service providers (such as payment processors, marketing partners, employee benefits partners; identity verification providers); government regulators; law enforcement.
    

        Sensitive Information such as government issued identity document such as passport, driver’s license, national identity card, state ID card, tax ID number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with legal obligations under applicable financial regulation and law.
        Information you provide us; information collected from third parties.
        To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; internal research and development.
        Service providers (such as payment processors, employee benefits partners; identity verification providers); government regulators; law enforcement.
    

        Commercial information such as bank account information, payment card primary account number (PAN), transaction history, and/or tax identification number.
        Information you provide us; Information collected from third parties; information we may receive from third-party marketing or data partners.
        To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; internal research and development.
        Service providers (such as payment processors, employee benefits partners); government regulators; law enforcement.
    

        Electronic network activity such as browsing or search history, IP address, website interactions and advertisement interactions.
        Information automatically collected from visitors to our website.
        Audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; engage in marketing activities; internal research and development.
        Service providers (such as payment processors, marketing partners, employee benefits partners); government regulators; law enforcement.
    

        Geolocation data 
         IP address; website cookies
        Website traffic; website and customer security; website performance 
        Service providers (such as payment processors and marketing partners); government regulators; law enforcement.
    

        Audio, video, photographs or similar information such as customer service calls.
        Information you provide us; information we collect for security purposes.
        Audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; engage in marketing activities; internal research and development.
        Service providers (such as payment processors and marketing partners); government regulators; law enforcement.
    

        Professional, educational or employment related information including office location, job title, and/or description of role.
        Information you provide us; information collected from third parties; information we observe in connection with vendor or employee oversight.
        To maintain legal and regulatory compliance; to review and process your employment applications; to engage in marketing activities.
        Service providers (such as employee benefits partners and identity verification providers).
    

        Inferences drawn from the above about your preferences, characteristics, etc.
        Internal analytics.
        To engage in marketing activities; internal research and development.
        Service providers (such as marketing partners).
    

Category of Personal Information (PI) collected	Sources of PI	Purposes of collecting PI	Categories of third parties to whom we disclose PI
Identifiers such as full name, date of birth, nationality, gender, email address, phone number or postal address.	Information you provide us; information collected from third parties; information we may receive from third-party marketing and data partners.	To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; engage in marketing activities; internal research and development.	Service providers (such as payment processors, marketing partners, employee benefits partners; identity verification providers); government regulators; law enforcement.
Sensitive Information such as government issued identity document such as passport, driver’s license, national identity card, state ID card, tax ID number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with legal obligations under applicable financial regulation and law.	Information you provide us; information collected from third parties.	To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; internal research and development.	Service providers (such as payment processors, employee benefits partners; identity verification providers); government regulators; law enforcement.
Commercial information such as bank account information, payment card primary account number (PAN), transaction history, and/or tax identification number.	Information you provide us; Information collected from third parties; information we may receive from third-party marketing or data partners.	To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; internal research and development.	Service providers (such as payment processors, employee benefits partners); government regulators; law enforcement.
Electronic network activity such as browsing or search history, IP address, website interactions and advertisement interactions.	Information automatically collected from visitors to our website.	Audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; engage in marketing activities; internal research and development.	Service providers (such as payment processors, marketing partners, employee benefits partners); government regulators; law enforcement.
Geolocation data	IP address; website cookies	Website traffic; website and customer security; website performance	Service providers (such as payment processors and marketing partners); government regulators; law enforcement.
Audio, video, photographs or similar information such as customer service calls.	Information you provide us; information we collect for security purposes.	Audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; engage in marketing activities; internal research and development.	Service providers (such as payment processors and marketing partners); government regulators; law enforcement.
Professional, educational or employment related information including office location, job title, and/or description of role.	Information you provide us; information collected from third parties; information we observe in connection with vendor or employee oversight.	To maintain legal and regulatory compliance; to review and process your employment applications; to engage in marketing activities.	Service providers (such as employee benefits partners and identity verification providers).
Inferences drawn from the above about your preferences, characteristics, etc.	Internal analytics.	To engage in marketing activities; internal research and development.	Service providers (such as marketing partners).

We do not collect the following categories of personal information: Biometric information

Other Automatically Collected Information

Our servers automatically collect limited information about your computer when you visit our sites. This information may include the type of browser software you use, the operating system you are running, the IP address assigned to your computer or Internet connection, and the IP address of the website, if any, that referred you to our sites. We use this information to understand how visitors navigate through our sites, to enhance your experience while using our site, and to make the materials we post as valuable to visitors as possible.

We process this personal information as necessary for us:

To provide our Services or to make the sites available to you;
To fulfill our legitimate interests, including to manage our business operations; to take steps to prevent, detect or investigate crime, fraud, misconduct or any unlawful action or omission; to comply with policies and procedures under applicable regulations, guidelines or notices as well as our own policies and procedures;
To inform you of our Services and relevant news; and
For other purposes with notice to you and with your consent where necessary.

Legitimate Interests/Consent

To the extent we rely on our legitimate interests as a legal basis for processing of your personal information, we have considered the balance between our own interests (among other things, the lawful and efficient operation of our Services) and your interests and we believe that (a) you would reasonably expect us to carry out the kind of processing referenced above and (b) such processing will not cause you any harm and/or will not seriously impact your rights and freedoms with regard to data privacy. You have the right to withdraw any consent given to us for the processing of your personal information.

Disclosures of Personal Information

In order for us to provide our Services, we may share your personal information with the following categories of recipients:

Service Providers, including those who work to enhance our Site or Services and to protect the security of COMPANY systems.
Partners, including, to provide our Services to you.
Legal/Regulatory Authorities, including to respond to a subpoena or court order, judicial process, or regulatory inquiry; to defend against fraud, lawsuits, claims or other liabilities; and to prevent physical harm or financial loss in connection with any suspected or actual illegal activity.

Cross-Border Transfers

Irrespective of where you are located, we store all of your Personal Information in the United States. You understand that by providing us your Personal Information you are transmitting it to us in the United States.

Retention of Personal Information

We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. If we collect any biometric information about you, we will not store that information for longer than 3 years.

Data Subject Rights

You have a number of rights under applicable data protection laws in relation to your personal information. Under certain circumstances, you have the right to:

Have access to your personal information by submitting a request to us;
Have your personal information deleted;
Have your personal information corrected if it if wrong;
Have the processing of your personal information restricted;
Object to further processing of your personal information, including to object to marketing from us;
Make a data portability request;
Withdraw any consent you have provided to us;
Restrict any automatic processing of your personal information; and
Complain to the appropriate Supervisory Authority.

Contact Us

If you have any questions regarding this Privacy Notice or our privacy practices or wish to exercise any of the aforementioned rights, please contact us via email at privacy@lionheartstrategic.com.

You may also write to us at the following address:

Lionheart Strategic Management, LLC
Attn: Legal Department
605 Third Avenue, 36th Floor
New York, NY 10158