Information we collect
We gather only the data required to deliver our investment products, comply with regulation, and ensure platform integrity.
- Identity & contact details: name, email, phone number, residency, and professional affiliation.
- Verification records: government-issued identification, accreditation documentation, or KYC materials.
- Financial information: bank references, wallet addresses, and transaction history submitted during onboarding.
- Technical data: device identifiers, browser type, IP address, and analytics on how you interact with our sites.
How we use data
Processing is governed by contractual necessity, legitimate interest, and regulatory requirements.
- Structuring and administering investment mandates, capital calls, and distributions.
- Providing personalized portfolio reporting, alerts, and investor communications.
- Maintaining compliance with AML, KYC, and securities regulations across jurisdictions.
- Monitoring for fraud, intrusion attempts, and anomalous account activity.
- Improving our digital experience through aggregated analytics and feedback.
When we share information
ZeroNine Holdings never sells client information. Limited sharing occurs in tightly controlled scenarios:
- Regulatory filings or lawful requests from supervisory authorities and courts.
- Specialist vendors under confidentiality agreements who support custody, payments, analytics, or communication services.
- Corporate transactions, including mergers or asset transfers, where counterparties accept equivalent privacy safeguards.
- Risk mitigation circumstances where disclosure is necessary to protect investors, personnel, or company rights.
Cookies & tracking
We employ first-party cookies and similar technologies to maintain security and deliver insight.
- Essential cookies maintain session integrity for authenticated portals.
- Analytics cookies help us understand aggregated traffic patterns and page performance.
- Preference cookies remember language, accessibility, and notification settings.
- You may adjust cookie preferences within your browser; disabling some features may limit site functionality.
Security commitments
We align our controls with SOC 2 and ISO 27001-aligned practices to preserve confidentiality, integrity, and availability.
- Encryption of sensitive records in transit and at rest with industry-standard key management.
- Role-based access controls, audit logging, and multi-factor authentication for internal systems.
- Vendor risk assessments and contractual safeguards for all third-party processors.
- Annual penetration testing and continuous vulnerability monitoring.
Your privacy rights
Depending on your jurisdiction, you may exercise the following rights by contacting our privacy office:
- Request access to the personal data we hold about you and obtain a copy.
- Correct, update, or delete information where legally permissible.
- Restrict or object to certain processing, including direct marketing communications.
- Request data portability for information you provided to us.
- Lodge a complaint with your supervisory authority if you believe your rights are infringed.
Policy updates
We review this document at least annually or when regulations change. Material updates will be communicated through investor correspondence and highlighted on this page with a revised effective date.
Contact us
For privacy questions, data requests, or escalation, reach our governance desk at:
- Email: privacy@zeronineholdings.com
- Phone: +1 (646) 555-0199
- Mailing: ZeroNine Holdings, 745 Fifth Avenue, New York, NY 10151
