Privacy Policy

Privacy Policy Overview

Last Updated: January 1, 2024

Zentra Capital is committed to maintaining the confidentiality and security of personal information entrusted to us by our clients. This Privacy Policy explains our practices regarding the collection, use, and protection of your personal information and your rights concerning this information.

Scope of This Policy

This Privacy Policy applies to:

• Current and former clients of Zentra Capital
• Prospective clients who have provided information to us
• Visitors to our website and digital platforms
• Individuals whose personal information we may obtain through third parties
• All subsidiaries and affiliates of Zentra Capital

Information We Collect

Personal Information

We collect personal information necessary to provide investment management services and comply with regulatory requirements. This may include:

Category	Types of Information
Identity Information	Name, address, phone number, email address, date of birth, Social Security number, government-issued identification
Financial Information	Income, net worth, investment experience, risk tolerance, financial goals, account balances, transaction history
Employment Information	Employer name, job title, work address, professional affiliations
Regulatory Information	Accredited investor status, qualified purchaser status, beneficial ownership information
Digital Information	IP address, browser type, device information, website usage patterns, cookies

Sources of Information

We obtain personal information from various sources:

• Directly from you: Through applications, forms, consultations, and ongoing communications
• From your transactions: Account activity, investment performance, and service usage
• From third parties: Credit bureaus, identity verification services, regulatory databases, and other financial institutions
• From our website: Contact forms, downloads, and browsing activity
• From public sources: Publicly available information to verify identity and conduct due diligence

How We Use Your Information

Primary Uses

We use your personal information for legitimate business purposes, including:

• Investment Management: Providing investment advice, portfolio management, and related financial services
• Account Administration: Opening accounts, processing transactions, maintaining records, and providing statements
• Regulatory Compliance: Meeting anti-money laundering (AML), know-your-customer (KYC), and other regulatory requirements
• Risk Management: Assessing suitability, monitoring for suspicious activity, and managing operational risks
• Client Communication: Responding to inquiries, providing updates, and delivering important notices
• Service Improvement: Analyzing usage patterns to enhance our services and client experience

Marketing and Communications

With your consent, we may use your information to:

• Send periodic newsletters and market updates
• Provide information about new investment strategies or services
• Invite you to educational events or webinars
• Conduct client satisfaction surveys

You may opt out of marketing communications at any time by contacting us or using unsubscribe links in our communications.

Information Sharing and Disclosure

When We Share Information

We do not sell personal information to third parties. We may share your information in the following circumstances:

• Regulatory Requirements: When required by law, regulation, or legal process
• Fraud Prevention: To detect, prevent, or respond to fraud or illegal activities
• Business Transfers: In connection with mergers, acquisitions, or sale of business assets
• Consent: When you have given explicit consent to share information
• Affiliates: With Zentra Capital affiliates for legitimate business purposes

Third-Party Services

Our services may involve third parties such as:

• Investment custodians and prime brokers
• Fund administrators and transfer agents
• Independent auditors and legal advisors
• Technology and cybersecurity providers
• Regulatory reporting services

Data Security and Protection

Security Measures

We implement comprehensive security measures to protect your personal information:

• Encryption: Data is encrypted both in transit and at rest using industry-standard protocols
• Access Controls: Strict access controls limit who can view your information on a need-to-know basis
• Physical Security: Our facilities are secured with controlled access and surveillance systems
• Cybersecurity: Regular security assessments, monitoring, and incident response procedures
• Employee Training: Regular training on data protection and confidentiality requirements
• Vendor Management: Due diligence and ongoing monitoring of third-party service providers

Data Retention

We retain personal information for as long as necessary to:

• Provide ongoing services to you
• Comply with legal and regulatory requirements
• Resolve disputes and enforce agreements
• Maintain business records for legitimate purposes

When information is no longer needed, we securely dispose of it in accordance with our data retention policies and applicable regulations.

Your Privacy Rights

Access and Control

You have certain rights regarding your personal information:

• Access: Request access to personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of personal information, subject to legal and regulatory requirements
• Portability: Request a copy of your information in a structured, machine-readable format
• Restriction: Request restriction of processing in certain circumstances
• Objection: Object to processing for direct marketing purposes

Exercising Your Rights

To exercise your privacy rights or submit privacy-related requests:

• Email us at: info@zentra.capital
• Contact your client relationship manager
• Submit a written request to our office address

We will respond to your request within the timeframes required by applicable law, typically within 30 days.

Cookies and Website Technologies

Use of Cookies

Our website uses cookies and similar technologies to:

• Enable website functionality and security
• Remember your preferences and settings
• Analyze website usage and performance
• Provide personalized content and experiences

Types of Cookies

Cookie Type	Purpose
Essential Cookies	Required for website operation and security
Performance Cookies	Collect anonymous usage statistics
Functional Cookies	Remember preferences and settings
Marketing Cookies	Deliver relevant content and advertisements

You can control cookie settings through your browser preferences. However, disabling certain cookies may affect website functionality.

Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, services, or applicable laws. We will notify you of material changes through:

• Email notification to your registered email address
• Notice on our website
• Written communication for significant changes

Your continued use of our services after receiving notice of changes constitutes acceptance of the updated Privacy Policy.

Previous Versions

Previous versions of this Privacy Policy are available upon request and may be relevant for understanding how we previously handled your information.