Legal · Privacy Policy
Privacy Policy
Capitoline Global, LLC
This Privacy Policy explains how Capitoline Global, LLC (“Capitoline,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards your information when you visit our website at capitolineglobalgroup.com or contact us in connection with our services.
Please read this Privacy Policy carefully. By accessing or using our website, submitting a contact or enquiry form, or communicating with us by email, you acknowledge that you have read and understood this policy. If you do not agree with its terms, please discontinue use of our website.
01
Information We Collect
We collect information you provide directly to us, information collected automatically when you use our website, and information from third-party sources where applicable.
1.1 Information You Provide Directly
We collect personal information you voluntarily submit to us through our website, including through our contact form, email correspondence, and demo request submissions. This information may include:
- Contact information— First name, last name, business email address, and telephone number
- Professional information— Company or firm name, job title, and type of firm (e.g. hedge fund, investment bank, wealth manager)
- Enquiry content— The subject and content of your message, including any details you choose to provide about your technology requirements, use case, or business needs
- Communication preferences— Areas of interest you indicate (e.g. CapitolineFIX, Alpha News Aggregator, Blockchain services) and how you heard about us
- Newsletter subscriptions— Email address and name provided when subscribing to Capitoline Intelligence, our periodic market insights digest
1.2 Information Collected Automatically
When you visit our website, certain information is collected automatically by our website infrastructure and third-party analytics tools. This may include:
- Usage data— Pages visited, time spent on each page, navigation path through the website, and referring URL
- Device information— Browser type and version, operating system, device type (desktop, mobile, tablet), and screen resolution
- IP address— Your Internet Protocol address, which may be used to derive approximate geographic location (city or country level)
- Cookie data— Information stored in cookies and similar tracking technologies as described in Section 4 of this policy
1.3 Information We Do Not Collect
Our website is an informational and lead-generation platform. We do not collect or process:
- Payment card details or banking information through this website
- Government identification numbers or financial account credentials
- Sensitive personal data including health information, racial or ethnic origin, political opinions, or biometric data
- Data from minors under the age of 18 (see Section 10)
02
How We Use Your Information
We use the personal information we collect for the following purposes:
| Purpose | Description |
|---|---|
| Responding to enquiries | To respond to contact form submissions, demo requests, and email enquiries — including routing your message to the most relevant member of our team. |
| Business communications | To communicate with you about our products, services, pricing, and how Capitoline may be able to meet your technology requirements. |
| Newsletter delivery | To send Capitoline Intelligence — our periodic capital markets technology insights digest — to subscribers who have opted in. |
| Website improvement | To analyse how visitors use our website using aggregated and anonymised analytics data, enabling us to improve content, navigation, and performance. |
| Security & fraud prevention | To monitor for and protect against unauthorised access, fraudulent submissions, spam, and other malicious activity on our website. |
| Legal compliance | To comply with applicable laws, regulations, legal proceedings, or governmental requests where required. |
| Business records | To maintain records of client and prospect interactions in support of our legitimate business operations. |
We will not use your personal information for purposes materially different from those described above without first notifying you and, where required, obtaining your consent.
03
Legal Basis for Processing
Capitoline Global, LLC is headquartered in New York, USA. We process personal information in accordance with applicable privacy laws including, where relevant, the California Consumer Privacy Act (CCPA), the EU General Data Protection Regulation (GDPR) for individuals located in the European Economic Area (EEA), and the UK GDPR for individuals located in the United Kingdom.
Where GDPR or UK GDPR applies to our processing of your personal data, we rely on the following legal bases:
- Legitimate interests (Article 6(1)(f) GDPR)— Processing your enquiry, communicating about our services, and maintaining business records are necessary for our legitimate commercial interests, which do not override your fundamental rights and freedoms.
- Contract performance (Article 6(1)(b) GDPR)— Where we are in a contractual relationship or pre-contractual discussions with you or your organisation, processing is necessary to fulfil or prepare for that contract.
- Consent (Article 6(1)(a) GDPR)— For newsletter subscriptions and any optional marketing communications, we rely on your freely given, specific, and informed consent, which you may withdraw at any time.
- Legal obligation (Article 6(1)(c) GDPR)— Where processing is required to comply with a legal obligation applicable to Capitoline.
Please read this Privacy Policy carefully. By accessing or using our website, submitting a contact or enquiry form, or communicating with us by email, you acknowledge that you have read and understood this policy. If you do not agree with its terms, please discontinue use of our website.
04
Cookies & Tracking Technologies
Our website uses cookies and similar tracking technologies to improve your browsing experience, analyse website traffic, and understand how visitors engage with our content.
4.1 What Are Cookies
Cookies are small text files placed on your device by a website when you visit it. They are widely used to make websites work efficiently and to provide information to the website owner. Cookies may be “session cookies” (deleted when you close your browser) or “persistent cookies” (which remain on your device until they expire or are deleted).
4.2 Types of Cookies We Use
| Cookie Type | Provider | Purpose | Duration |
|---|---|---|---|
| Essential / Functional | Capitoline / WordPress | Necessary for the website to function correctly. Includes session management, security tokens, and form submission handling. | Session |
| Analytics | Google Analytics 4 | Collects anonymised information about how visitors use the website — pages visited, time on site, traffic sources. Helps us improve the website experience. | Up to 2 years |
| Preference | WordPress / Elementor | Remembers your preferences such as language or display settings to improve your experience on return visits. | Up to 1 year |
| Security | WordPress / WPForms | Used to protect the website and contact forms against spam, CSRF attacks, and malicious submissions. | Session |
4.3 Google Analytics
We use Google Analytics 4 (GA4), a web analytics service provided by Google LLC, to analyse website traffic and user behaviour in aggregate. Google Analytics sets cookies on your device and transmits data to Google servers, which may be located in the United States.
The information collected by Google Analytics about your use of this website is used to compile reports and to help us improve the website. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on or by adjusting your browser’s cookie settings. For more information on how Google uses data, please visit policies.google.com/privacy.
4.4 Managing Cookies
Most web browsers allow you to control cookies through their settings preferences. You can typically configure your browser to refuse all cookies, accept only certain types of cookies, or to notify you when a cookie is being placed. Please note that disabling certain cookies may affect the functionality of our website.
For more information about managing cookies, visit allaboutcookies.org.
05
Sharing Your Information
We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your information in the following limited circumstances:
5.1 Service Providers
We work with trusted third-party service providers who assist us in operating our website and conducting our business. These providers are contractually obligated to handle your data securely and only for the purposes we specify. Current categories of service providers include:
- Web hosting and infrastructure— WordPress hosting providers who store and serve our website files
- Email delivery— Email service providers that deliver contact form notifications to our team at info@capitolineglobalgroup.com
- Analytics— Google LLC (Google Analytics 4) for aggregated website traffic analysis
- Newsletter delivery— Email service providers used to distribute Capitoline Intelligence to subscribers
- Customer relationship management— CRM tools used internally to manage business communications and prospect records
5.2 Affiliated Entities
We may share information within the Capitoline group of companies — including our offices in New York, Puerto Rico, and Pune, India — for the purposes of responding to your enquiry and delivering our services.
5.3 Legal Requirements
We may disclose your personal information where required to do so by law, court order, regulatory authority, or governmental request, including to comply with applicable financial services regulations.
5.4 Business Transfers
In the event of a merger, acquisition, reorganisation, or sale of all or part of Capitoline’s assets, your personal information may be transferred to the acquiring entity. We will notify you by email and/or a prominent notice on our website of any such change in ownership or control of your personal information, and you will be informed of your choices in that event.
5.5 With Your Consent
We may share your information with third parties in ways not described above when we have obtained your explicit consent to do so.
We do not sell personal information. Capitoline Global, LLC does not sell personal information to data brokers, advertising networks, or any third parties for commercial gain, as defined under the California Consumer Privacy Act (CCPA) or any other applicable privacy law.
06
Data Retention
We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, maintain accurate business records, comply with our legal obligations, resolve disputes, and enforce our agreements.
| Data Category | Retention Period | Basis |
|---|---|---|
| Contact form submissions (general enquiries) | 3 years from submission, or until client relationship ends | Legitimate business interest / relationship management |
| Active client and prospect records | Duration of relationship + 7 years | Legal and regulatory compliance |
| Newsletter subscriber records | Until unsubscribe request is received + 30 days | Consent-based — deleted promptly upon withdrawal |
| Website analytics data (Google Analytics) | Up to 26 months (Google’s default retention setting) | Legitimate interest in website improvement |
| Security logs and fraud prevention data | Up to 12 months | Legitimate security interest |
When personal information is no longer required for the purpose for which it was collected and no legal retention obligation applies, we will delete or anonymise it in a secure manner.
07
International Data Transfers
Capitoline Global, LLC is headquartered in New York, USA, and operates across three global hubs: New York, Rio Grande (Puerto Rico), and Pune, India. Information you submit through our website may be accessed by staff and systems in any of these locations in order to respond to your enquiry and deliver our services.
If you are located in the European Economic Area (EEA) or the United Kingdom, please be aware that your personal information will be transferred to and processed in the United States and India — countries that may not provide the same level of data protection as your home jurisdiction.
Where such transfers occur, we ensure appropriate safeguards are in place, which may include:
- Standard Contractual Clauses (SCCs) approved by the European Commission for transfers to third countries
- Adequacy decisions issued by the European Commission or UK Information Commissioner’s Office (ICO), where applicable
- Binding corporate policies and contractual obligations with internal teams and service providers
If you have questions about the safeguards applicable to international transfers of your data, please contact us using the details in Section 13.
08
Your Privacy Rights
Depending on your location, you may have specific rights regarding your personal information. We are committed to honouring these rights in accordance with applicable law.
8.1 Rights Under GDPR / UK GDPR (EEA and UK Residents)
If you are located in the European Economic Area or the United Kingdom, you have the following rights:
- Right of access— You have the right to request a copy of the personal information we hold about you.
- Right to rectification— You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.
- Right to erasure (“right to be forgotten”)— You have the right to request that we delete your personal information where it is no longer necessary for the purpose for which it was collected, or where you have withdrawn consent.
- Right to restriction of processing— You have the right to request that we restrict processing of your personal information in certain circumstances.
- Right to data portability— Where processing is based on your consent or a contract, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
- Right to object— You have the right to object to processing of your personal information based on our legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
- Right to withdraw consent— Where we rely on your consent as the legal basis for processing (e.g. newsletter subscriptions), you may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.
- Right to lodge a complaint— You have the right to lodge a complaint with your local data protection authority. In the EU, this is your national supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO):ico.org.uk.
8.2 Rights Under the CCPA (California Residents)
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA):
- Right to know— You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the purposes for collection, and any third parties with whom we have shared it.
- Right to delete— You have the right to request deletion of personal information we have collected from you, subject to certain exceptions.
- Right to correct— You have the right to request correction of inaccurate personal information we hold about you.
- Right to opt out of sale / sharing— We do not sell or share personal information as defined under the CCPA. No opt-out action is required.
- Right to non-discrimination— We will not discriminate against you for exercising any of your CCPA rights.
8.3 How to Exercise Your Rights
To exercise any of the rights described above, please contact us by email at info@capitolineglobalgroup.com with the subject line “Privacy Rights Request.” We will respond to all verifiable requests within the timeframes required by applicable law — generally within 30 days for GDPR requests and 45 days for CCPA requests.
We may need to verify your identity before processing your request. We will not charge a fee for responding to your request unless it is manifestly unfounded, excessive, or repetitive.
8.4 Unsubscribing from Communications
You may unsubscribe from Capitoline Intelligence newsletter communications at any time by clicking the unsubscribe link included in every email, or by contacting us at info@capitolineglobalgroup.com. We will process your request within 5 business days.
09
Data Security
Capitoline Global, LLC implements appropriate technical and organisational measures to protect your personal information against unauthorised access, accidental loss, destruction, disclosure, or alteration.
Specific security measures we employ include:
- Transport Layer Security (TLS/SSL) encryption for all data transmitted between your browser and our website
- HTTPS protocol enforced site-wide on capitolineglobalgroup.com
- Regular WordPress security updates, patching, and vulnerability monitoring
- Access controls limiting staff access to personal information on a need-to-know basis
- CSRF protection and spam filtering on all contact form submissions via WPForms
- Secure email infrastructure for receiving and handling contact form responses
Important: No method of transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and, where required, the relevant supervisory authority, in accordance with applicable law.
10
Children's Privacy
Our website and services are directed exclusively at institutional financial services professionals and business entities. They are not directed at, and we do not knowingly collect personal information from, individuals under the age of 18.
If you are under 18 years of age, please do not submit any personal information through our website or contact forms. If we become aware that we have inadvertently collected personal information from a person under 18, we will take prompt steps to delete that information from our records.
If you believe we may have collected information from or about a minor, please contact us immediately at info@capitolineglobalgroup.com.
11
Third-Party Links & External Platforms
Our website contains links to third-party websites, platforms, and products that are not operated or controlled by Capitoline Global, LLC. These include, but are not limited to:
- varropower.com— Varro power trading analytics platform
- plutusdigitalasset.com— Plutus Digital Asset Platform
- LinkedIn and other social media platforms linked from our website
- YouTube (for embedded product video content)
This Privacy Policy applies solely to capitolineglobalgroup.com and does not apply to any third-party websites, platforms, or services. We have no control over and assume no responsibility for the privacy practices, content, or actions of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.
The inclusion of a link on our website does not constitute our endorsement, recommendation, or approval of the linked website or its operator.
12
Changes to This Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or website functionality. When we make material changes, we will:
- Update the “Last Updated” date at the top of this page
- Post the revised Privacy Policy at this URL (capitolineglobalgroup.com/privacy-policy/)
- Where changes are significant, provide additional notice by email to registered subscribers or by a prominent notice on our homepage
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of our website following the posting of changes to this policy will constitute your acknowledgment of those changes.
The version date at the top of this page indicates when this policy was most recently updated. Archived versions of previous privacy policies are available on request by contacting us at info@capitolineglobalgroup.com.
13
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us using the details below. We are committed to resolving any privacy-related concerns promptly and transparently.
Privacy Enquiries — Capitoline Global, LLC
For all privacy-related requests, rights exercises, or general questions about this policy, please contact our team directly. We respond to all privacy enquiries within 2 business days.
Subject line: “Privacy Policy Enquiry” or “Privacy Rights Request”