Blue Tear Capital (BlueTearCapital, “we”, us,” or “our”) respects your privacy and recognizes the importance of providing a safe environment for your personal information. Therefore, we strive to be transparent about how we collect, manage, and process your personal data.

 Blue Tear Capital is a Communication and Strategic PR Solution provider while acting as an intermediary service provider, offering a range of services to corporations and businesses, such as Financial Consulting, Investor overviews and alerts, advisory counselling, and stock exchange listing.

 We respect and are committed to protecting your privacy as well. This Privacy Policy describes how we collect, use, share, manage, and otherwise process personal information about you and others in connection with our Platform. If you don’t agree to our privacy policy, please do not use our Platform.

Who is responsible for processing your Personal Data?

Blue Tear Capital, 463 7th Ave., NY 10018, USA, Phone: +1-212-695-1962, Email: [email protected], is responsible (“the data controller“) for the processing of the user’s personal data.

What types of Personal data do we collect, store, and process?

We collect, use, store, and transfer various types of personal data. In principle, we do not collect “special categories of personal data” and do not ask you to provide them. This is specially protected information, such as data on health, religion, political or philosophical beliefs, sexual preferences, and orientations.

 We collect and process personal data about you in connection with our relationship with you. We process the following types and categories of user personal data:

2.1 Personal Data Given By You

You share or are asked to share certain information, such as:

• The business contact information you provide us: name, surname (title), Job Title, email address, company name, business address, telephone landline or mobile number
• Types of Stock Market Stakeholders: for example, shareholders, investors, prospective investors, analysts, the press, public commentators, and/or professional service providers
• Additional information given to us during our business relations and collaborations, such as : registered information given at events, forming a list of participants, name badges, etc.
• Information given as part of communication history and content: If you report a problem, make an inquiry, or make a suggestion, we may need to process your personal data and keep a log of that communication.

2.2 Personal Data Collected From Other Third

We get personal data about you from other sources, including:

• Data originating from publicly accessible sources or lawfully transmitted by other third parties (such as controllers), to the extent necessary to fulfil our obligations: share registration data
• We collect personal data that you have already made public:  We may collect personal information through public websites and other public sources.
• We receive your personal data from third parties that provide it to us, such as your advisors, intermediaries, relevant legal and regulatory authorities, or other third parties:  This includes, but is not limited to, the information we receive for the purposes of our Know Your Customer procedures (including, but not limited to, anti-money laundering, anti-terrorist financing, political exposure testing, and sanctions testing).

1. Do We Collect Data From Minors And Underage People ?

 Our investor relations and PR solutions are not intended for persons under the age of 18. If we become aware that we have collected personal information from a data subject under the age of 18, we will delete that information as soon as possible. Whenever you believe that the data subject may be under the age of 18, please contact us by email at [email protected]. 

1. For What Purpose Or Intent Do we Process User Data ?

We process user personal data for the following purposes:

Managing Relations

• To periodically inform investors and capital market participants about company news and developments.
• To process inquiries about the capital markets;
• Planning and execution of IR events (teleconferences, road shows, capital market days, etc.)
• For the operation of our investor website
• To track communications and reporting with capital market participants;

Maintenance Of The Official Register

• To the extent necessary for management in order to exercise rights as a shareholder

Organisation Of Meetings

• Organizing and administering Annual General Meetings (AGM), Extraordinary General Meetings (EGM), or other statutory meetings (including voting arrangements)
• To facilitate voting by shareholders at general meetings of shareholders
• For sending invitations to shareholders
• To answer questions before the general meeting of shareholders
• To process objections to resolutions or other directives relating to general meetings or internal meetings;

 Preventing fraud and illegal activity

• for the investigation of fraud and illegal activities
• Enforcement of our policies

Communication

• For the delivery of announcements
• To provide a response to your queries, requests, and complaints

Compliance For our Legal And Regulatory Obligations

• To determine legal requirements for the processing of your personal data (based on your location, such as your country);
• To respond to requests relating to your rights as a data subject;
• To comply with our legal obligations (such as tax, accounting obligations, etc.),
• To exercise our legal rights,
• To protect us from legal claims;
• To inform you of changes made to this privacy policy

1. On Which Legal Basis Do we Process User Personal Data ?

We process your personal data for the purposes described in this Privacy Statement based on the following legal bases:

• Performance of a contract: We process your personal data for the purpose of performing a contract to which you are a party, e.g., fulfilling obligations under our Articles of Incorporation, processing shareholder rights exercised by you, and contacting and communicating shareholder information.
• Compliance with legal obligations to which we are subject: We process your personal data for tax and accounting purposes, in cases of legal disputes, and to comply with legal obligations such as reporting obligations, obligations to cooperate with authorities, and statutory retention periods. We also process your personal data to create and update shareholder records and keep them up-to-date on issues relevant to them.
• Legitimate Interests: We process your personal data to the extent that the processing is necessary for our legitimate interests or those of a third party, and we apply appropriate security measures to protect your privacy. Our legitimate interest lies in regular or event-related information and communications with capital market participants and in defending our interests in the event of legal claims.

1. With Whom We Share User Personal Data ?

We will not pass your personal data on to third parties who are not authorized to process it. To manage our relationship with you, we may share your personal data internally with members of management, departments, and relevant technical support to the extent that access to your personal data is necessary to perform their job duties.

 In addition, we may share your personal information with the following recipients or categories of recipients: the following third parties in your investor relations, solely as necessary to achieve the purposes set out above: Allow us to collect your personal information in connection with our activities.

• Blue Tear Capital affiliates and subsidiaries
• External service providers
• Professional service providers
• Regulators, government authorities, courts, or law enforcement
• Other third parties:

 

1. Where would you process personal USER data?

Your personal data is generally stored on our servers. However, your information may be transferred outside of our legitimate geographical areas. We have implemented the European Commission’s standard data protection clauses (model clauses) to protect your personal information when it is transferred outside the EU or EEA. We have taken appropriate safeguards to protect it.

1. How Will We Protect User Personal Data?

We have employed appropriate technical and organizational security measures to protect your personal data against accidental, unlawful, or unauthorized destruction, loss, manipulation, alteration, access, disclosure, or use. We continuously update and test our security standards. In addition, we will take reasonable steps to ensure that third parties to whom we transfer your personal data provide an adequate level of protection for your personal data.

1. How Long Do We Store User Personal Data?

 We will not use or retain your personal information longer than is necessary to achieve the purpose for which it was collected, to comply with a legal obligation, to establish, exercise, or defend a legal claim, or to resolve a dispute. We will then delete or anonymize your personal data.

1. What are your rights regarding your personal data?

To the extent permitted by applicable data protection laws and regulations, you are entitled to have the following rights with respect to your personal data:

• Access the personal information that we currently hold about you.
• Request updates or corrections to the user’s personal data.
• Receive personal data in a structured, commonly used, and machine-readable format;
• Request the erasure of personal data.
• Restrict the processing of personal data.
• The user can withdraw his or her consent at any time related to the personal data.
• Object to processing for certain reasons;

To exercise these rights, send your request to the contact details below, including your name, email address, and a description of your request.

11. How can you contact us?

If you have any questions or queries regarding this Privacy Policy or the processing of your personal information, please contact us at Blue Tear Capital, 463 7th Ave., NY 10018, USA, phone +1-212-695-1962, or email [email protected].

1.  How often Do We Update This privacy Notice ?

We regularly review and update this Privacy Policy. In the event of material changes that materially affect the processing of your personal data, we will notify you by e-mail if we have your e-mail address.

 

This Privacy Notice was last reviewed and updated on June 23, 2013.