For Investors and Clients located in the European Union Only.
Madison Capital Funding GDPR Privacy Notice
Madison Capital Funding LLC and its subsidiaries (referred to collectively as “Madison Capital” or “we” or “our“) is committed to respecting the privacy of individuals, including its clients.
Madison Capital owns and operates this site (www.mcfllc.com).
For the purposes of applicable data protection law (in particular, the General Data Protection Regulation (EU) 2016/679 (the “GDPR“)), the entity referred to above is the “data controller” of your personal data.
Personal Data We collect
We may collect and process the following personal data:
- Information you give us:
- If you are enquiring about or using our products and services (including, where you invest in Madison Capital managed funds, then we may process your personal data – including your name, address, e-mail address and phone number, financial information, personal description, photograph, ID documentation (including your passport or ID card), marital status, information about you dependents or beneficiaries, as well as information about your investments in Madison Capital funds.
- You may give us information about you when you complete a form on our site or by corresponding with us by phone, e-mail or other electronic means, or in writing. This includes information you provide when you search our site, make enquiries, purchase our services, submit information or content to our site, when you report a problem with our site – including your name, email address, gender, postal address, telephone and fax.
- Information we collect about you: With regard to each of your visits to our site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products, services or issues you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our offices.
- Information we receive from other sources:
- Madison Capital delegates certain administrative services in relation to its funds to certain third-parties who act as Madison Capital’s administrative and transfer agent in relation to its funds. This means that third-parties are primarily responsible for collecting personal data of our fund investors, holding it on Madison Capitals’s behalf, and providing it to Madison Capital for reporting purposes.
- We are part of a global group of companies which manage funds and provide other financial services. Where you have requested services which involve one or more of our subsidiaries and/ or affiliates, we will tell you, and we may receive relevant information from our subsidiaries and/ or affiliates for the purposes of those services.
- We also work closely with third parties (for example, banks and other financial institutions, business partners, legal or other consultants, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
- Information about other people: If you provide information to us about any person other than yourself, such as your relatives, your executors, next of kin, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.
We may ask you for consent to collect or process your personal data on certain occasions, for example, and as stated below, where necessary in order to contact you with information about products and services that might be of interest to you. We also process your personal data when we need to do this to fulfil a contract with you, such as to give effect to your investment in a Madison Capital fund, or when required by law, such as if we receive a request from law enforcement or other government officials.
We also process your personal data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we have a legitimate interest in the effective administration of the Madison Capital funds and our business, and in ensuring the security and integrity of our sites.
Disclosure of Your Personal Data
We may share your personal data with our subsidiaries and/ or affiliates.
We may also share your personal data with trusted third parties including:
- Banks and other financial institutions which, for example, act as transfer agents or custodians of the Madison Capital funds;
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
- Legal or other advisers, consultants and other professional experts, complainants, correspondents and enquirers, and suppliers and service providers of any of the above, and each of their associated businesses;
- Business partners, suppliers and sub-contractors only for the purposes of performance of any contract we enter into with them or you. We take reasonable steps to ensure that our staff protect your personal data, and are aware of their information security obligations; and
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal data to third parties:
- If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If Madison Capital, its business, or its assets are acquired by a third party, in which case personal data held by it about its users, suppliers, or customers will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or if we reasonably consider this necessary; or to protect the rights, property, or safety of Madison Capital, our users, our customers, or others; and
- For the purposes of crime prevention and fraud protection.
We, or trusted third parties on our behalf, may contact you by email or post with information about products and services that might be of interest to you. Where necessary, at the time that you provide your personal data to us, you will be given the opportunity to indicate whether or not you are happy for us to use your personal data in order to tell you about such products or services.
You can unsubscribe from this at any time by clicking on the link provided in the relevant email, or by emailing us using the contact details provided below.
Where We Store Your Personal Data and How We Protect it
Some of the Madison Capital subsidiaries and/ or affiliates and third parties to whom Madison Capital discloses your personal data (as described above) may be located in countries outside the EEA that do not provide a level of protection to personal data equivalent to that provided by your home country.
In order to provide adequate protection for these transfers, Madison Capital utilizes transfer mechanisms recognized by your home country, which may include executing appropriate contractual clauses based on and conforming to the EU model clauses. To obtain a copy of the transfer mechanism, please contact us using the details provided below.
We take reasonable steps to protect your personal data from loss or destruction. Where you have a username or password (or other identification information) which enables you to access certain services or parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
You have various rights with respect to our use of your personal data:
- Access: You have the right to request a copy of the personal data that we hold about you. Please note that there are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. You are entitled to see the personal data held about you. If you wish to do this, please contact us using the contact details provided below.
- Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
- Objecting: In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data. If you would like us to stop using your personal data, please contact us using the contact details provided below.
- Porting: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
- Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority or to seek a remedy through the courts.
Please note that there are exceptions to these rights, if, for example, we are under a legal obligation to continue to process your personal data.
When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.
How Long We Keep Your Personal Data
We will retain your personal data, whether or not your account is active, for as long as we believe it necessary or desirable to fulfil our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts.
Changes to our Privacy Notice
Any changes we may make to our Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Notice.
Questions, comments and requests regarding this Notice are welcomed and should be addressed to firstname.lastname@example.org.