Privacy Policy

Effective date: [EFFECTIVE DATE]
Last updated: [LAST UPDATED]

This Privacy Policy explains how [LEGAL ENTITY NAME], operating under the Rivendell brand ("Rivendell," "we," "us," or "our"), collects, uses, discloses, and protects information when you visit https://www.rivendell.capital and its associated language versions (the "Site").

This Policy applies to the Site only. It does not govern any investment management, advisory, account, custody, execution, or other service that may be provided under a separate written agreement.

1. Who is responsible for your information

The controller or business responsible for personal information processed through the Site is:

• Legal entity: [LEGAL ENTITY NAME]
• Jurisdiction of incorporation: [JURISDICTION OF INCORPORATION]
• Registered address: [REGISTERED ADDRESS]
• Privacy contact: [PRIVACY CONTACT EMAIL]
• Data Protection Officer or representative, if applicable: [DPO / EU OR UK REPRESENTATIVE DETAILS]

2. Information we collect

The Site is an informational website. It does not provide user accounts and is not intended to collect funds, trading instructions, private keys, seed phrases, passwords, exchange credentials, or API credentials.

When you visit the Site, we or our service providers may collect limited technical and usage information, including:

• IP address and approximate location derived from it;
• browser type and version, device type, operating system, language, and time zone;
• referring page or source, pages viewed, visit date and time, session duration, navigation path, and interactions with Site content;
• performance, diagnostic, security, and error logs; and
• cookie identifiers, analytics identifiers, and your cookie or privacy preferences.

We do not intentionally collect sensitive personal information through the Site. If the Site later introduces a contact form, eligibility review, account feature, newsletter, or other data-collection function, this Policy must be updated before that function is launched.

3. Cookies and similar technologies

We may use cookies, pixels, local storage, scripts, tags, or similar technologies for the following categories:

Where applicable law requires consent, non-essential analytics technologies will not be activated until you consent. Where applicable law permits privacy-preserving analytics for strictly statistical purposes without prior consent, we will use that approach only if the relevant conditions are met, including clear notice, data minimisation, aggregate results, no advertising or individual profiling, and a simple, free means to object.

You can change your preferences at any time through [COOKIE SETTINGS LINK OR CONTROL]. Blocking some technologies may affect certain Site functions.

4. How and why we use information

We may process information to:

• deliver, maintain, secure, and troubleshoot the Site;
• detect abuse, fraud, malicious activity, or technical failures;
• understand aggregate traffic, content engagement, and user journeys;
• improve Site content, navigation, accessibility, performance, and language support;
• remember language, cookie, and privacy choices;
• comply with legal obligations and respond to lawful requests; and
• establish, exercise, or defend legal claims.

Depending on the applicable law and the circumstances, our legal bases may include:

• our legitimate interests in operating, securing, and improving an informational corporate website;
• your consent for non-essential cookies or analytics where consent is required;
• compliance with legal obligations; and
• another lawful basis or statutory exception available under applicable law.

We do not use Site analytics to make decisions that produce legal or similarly significant effects about individual visitors.

5. How we disclose information

We may disclose limited information to:

• hosting, content-delivery, security, infrastructure, and technical support providers;
• analytics providers identified in our cookie settings or cookie table;
• professional advisers, auditors, insurers, or legal counsel where reasonably necessary;
• regulators, courts, law-enforcement bodies, or other authorities where required or permitted by law; and
• a buyer, successor, or relevant adviser in connection with a proposed or completed merger, restructuring, financing, or transfer of all or part of our business, subject to appropriate safeguards.

Our service providers may process information only for agreed purposes and subject to appropriate contractual and security obligations.

Rivendell does not sell personal information or share it for cross-context behavioural advertising.

6. International transfers

Some service providers may process information outside the country where you are located. Where required, we will use an appropriate transfer mechanism and safeguards, such as adequacy decisions, approved contractual clauses, or another lawful mechanism.

Before publication, insert the principal hosting and analytics locations here: [DATA HOSTING AND TRANSFER LOCATIONS / SAFEGUARDS].

7. Retention

We retain information only for as long as reasonably necessary for the purposes described in this Policy, including security, analytics, legal, and record-keeping needs. Current intended retention periods are:

• server and security logs: [RETENTION PERIOD];
• individual-level analytics data, if any: [RETENTION PERIOD];
• aggregate analytics reports: [RETENTION PERIOD]; and
• cookie-consent or objection records: [RETENTION PERIOD].

We may retain information longer where required by law or necessary to establish, exercise, or defend legal claims. We will delete or anonymise information when it is no longer needed.

8. Security

We use reasonable technical and organisational safeguards designed to protect information against unauthorised access, loss, misuse, alteration, or disclosure. No website or transmission method is completely secure, and we cannot guarantee absolute security.

9. Your privacy rights

Depending on where you live and subject to applicable exceptions, you may have the right to:

• receive information about how your personal information is processed;
• request access to or a copy of your personal information;
• request correction or deletion;
• request restriction of processing;
• object to certain processing;
• receive certain information in a portable format;
• withdraw consent at any time, without affecting earlier lawful processing;
• opt out of the sale or sharing of personal information, where applicable;
• limit certain uses of sensitive personal information, where applicable; and
• lodge a complaint with a competent privacy or data-protection authority.

Where applicable, you will not be discriminated against for exercising your privacy rights. To submit a request, contact [PRIVACY CONTACT EMAIL]. We may take reasonable steps to verify your identity and authority before acting on a request.

If we become subject to a browser-based opt-out signal such as Global Privacy Control, we will process that signal as required by applicable law.

10. Children

The Site is intended for institutional and professional audiences and is not directed to children. We do not knowingly collect personal information from anyone under 18 through the Site. If you believe a child has provided personal information to us, contact [PRIVACY CONTACT EMAIL].

11. Third-party websites

The Site may link to third-party websites or services. Their privacy practices are governed by their own notices, and we are not responsible for those practices. Review their privacy information before providing personal information.

12. Changes to this Policy

We may update this Policy to reflect changes in the Site, our practices, or applicable law. We will post the updated version on this page and change the "Last updated" date. Where required, we will provide additional notice or request renewed consent.

13. Contact us

Questions, requests, or complaints about this Policy may be sent to:

[LEGAL ENTITY NAME]
[REGISTERED ADDRESS]
[PRIVACY CONTACT EMAIL]
[DPO / EU OR UK REPRESENTATIVE DETAILS, IF APPLICABLE]