1. Information that we collect

1.1 Information you give us.
When you use the Site we may ask you to provide personal information such as contact details, identity documents, banking details, sources of funds and wealth and in the case of Issuers and Sellers information about your business including but not limited to company name, company size, address, contact details, nature of business, ownership structure, financial information and forecasts and information about persons associated with the business. Most of this information is to comply with our legal obligations and to fulfil our contractual obligations with you and other parties that use the Site. In some cases, sharing the information is necessary for us to provide our services.
1.2 Information we get from your use of our services and by communicating with us.
We collect information about the services you use and how you use them, such as when you view and interact with the Site or our advertisements. In addition, we may gather certain information about you, including details of your operating system, browser version, domain name and IP address using which you access the Site. We may also collect your Personal Data (any data relating to an identifiable natural person as defined in the Personal Data Protection Law) when you interact with our employees on the phone or in person and we may record those conversations, either because we are required to do so under regulation, or for training purposes so that we can improve our services.
1.3 Cookies.
We may set and access cookies and other similar technologies on your computer. These are small files that may reside on your computer’s hard drive that are accessible only by the website that placed them there and not by any other website. If we have third-party advertisements on the Site, those third parties may also place, set and access cookies on your computer. They do this to track how many unique users have seen an advertisement and to provide advertisements that are more relevant to a user's interests. We do not have access to these cookies and, other than allowing them to be served, we play no role in these cookies at all. Cookies placed by us will allow us to track your browsing behaviour, links clicked and to collect various data, including analytics about how you use our Site. This will allow us to provide you with a better experience on our Site, and to collect, analyse and improve the performance of our services. You can choose to enable or disable cookies in your web browser.  In addition, you may delete cookies that have already been placed on your hard drive.
1.4 Third party Links.
The Site may contain links to other websites. Bambucorn shall not be responsible for the Privacy Policies or the practices of third-party websites.

2. Data Protection Principles

Based on the Personal Data Protection Law, we are classified as a ‘Data Controller’. This means that we shall be responsible for determining the purposes and means of the Processing of Personal Data. Bambucorn will ensure that your Personal Data shall be:

• Processed fairly, lawfully and securely;
• Processed for specified, explicit and legitimate purposes in accordance with your rights not further Processed in a way incompatible with those rights;
• Adequate, relevant and not excessive in relation to the purposes for which it is collected and/or further processed;
• Accurate and where necessary, kept up to date and where inaccurate are Processed and rectified without delay;
• Kept in a form which permits your identification for no longer than is necessary for the purposes for which the Personal Data was collected or for which they are further Processed;
• Kept confidential and Processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful Processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures;
• Accessed and rectified by Data Subjects (as defined in the Personal Data Protection Law); and
• Default privacy preferences of the platform shall be set in a way that no more than the minimum Personal Data is obtained or collected and the Data Subject shall be: 
  • Prompted to actively select its privacy preferences on its first use; and
  • Able to easily change such preferences.

3. How we use your Information

We shall collect the following types of information: 

• Personal Details 

• Education & Training details

• Employment Details 

• Financial details 

• Photographs (of Data Subject and Data Subject’s documents)

We use the information we collect :

1. To comply with legal and regulatory obligations including the Financial Crime Module of Volume 5 of the CBB Rulebook:

• To confirm your identity to ensure you are eligible to use the services provided on the Site.

• To conduct required anti-money laundering checks in connection with the transactions you may conduct through the Site. 

• To ensure you are eligible to use the Site in accordance with other agreements that you may execute on the Site. 

• To enable us to comply with our compliance responsibilities and reporting to regulators and governmental authorities. 

    2. To carry out obligations under our contracts:

• To process and administer payments and investments in connection with the services provided on our Site. 

• In the case of Issuers and Sellers, to assess your suitability to execute a campaign on the Site, to verify and approve the disclosures you make in your campaign to potential investors, to provide you with any campaign marketing services and to facilitate the investment transactions.

• In the case of Clients, to facilitate any investments you make, to exercise any rights you may have by virtue of being a shareholder in any of the Issuers and Sellers and to provide Issuers and Sellers with information about the progress of their campaigns and your investments in it.

• In the case of Experts, to share information about you with Clients and Issuers and Sellers.

• In the case of Clients who have completed investments in Issuers and Sellers, to provide those businesses with information to fulfil obligations to you and us, and ensure compliance with their corporate or regulatory requirements, such as shareholder reporting.

     3. To ensure that the services To ensure that services provided by us through our Site operate effectively and to do this we may use your Personal Data to:

• To monitor, improve and administer the Site and the services provided on the Site.

• To contact you to ensure customer satisfaction in respect of our role as a service provider and assist you in getting the best value from our services.

• To respond to customer support or other enquiries requesting information. We may also intercept, record and/or monitor any communication(s) (including telephone calls or other electronic communications) between you and us. We may do so in order to resolve queries in the future and for the purposes of ensuring security, staff training and complying with our regulatory and legal responsibilities. In the case of communications by email you should note that, as emails are not encrypted (and may therefore be intercepted by third parties) and as the identity of the sender cannot be confirmed, you must not provide your security details by email.

      4. To facilitate communication between you and others, publicising our business, support industry research, and making that sure marketing, advertising and content we provide is effective.               We will only contact you for this purpose if you have consented to do so. 

4. Your Rights

You have the right to access any information we hold about you. You may ask us:

• To confirm in writing as to whether or not Personal Data relating to you is being Processed.
• To communicate to you in an intelligible form of the Personal Data undergoing Processing and of any available information as to its source.
• As appropriate, the rectification, erasure or blocking of Personal Data the Processing of which does not comply with the provisions of the Personal Data Protection Law (hereinafter referred to as “PDPL”).
• To stop at any time on reasonable grounds the Processing of Personal Data relating to yourself, subject to compliance with any applicable law.
•  To be informed before Personal Data is disclosed for the first time to third parties or used on their behalf for the purposes of direct marketing, and to be expressly offered the right to object to such disclosures or uses.
• To send you one copy of the Personal Data you have provided to us. To do so please contact us at contact@bambucorn.com. This will generally be provided to you free of charge, but we may charge a reasonable fee if the request is unfounded, excessive or repetitive. 

5. Choice

You can manage the kind of emails you receive from by notifying us at contact@bambucorn.com and instructing us to not process your Personal Data for marketing purposes. 

Currently, the Site makes use of strictly necessary cookies (cookies that are essential to the functioning of the website) and performance cookies (these cookies collect information about how you use the Site and none of the information collected can be used to you). You may choose to accept cookies or not via your browser settings. Please note that as and when new types of cookies are used on the Site, you shall be notified of the same. 

6. Accuracy and retention of Personal Data

If you see that any of your Personal Data included in the Site is inaccurate, please update it using the Site. Alternatively, if you believe that any Personal Data, we hold about you is inaccurate, please notify us at contact@bambucorn.com. It is your responsibility to ensure that any Personal Data you have provided to us remains accurate and to notify us if there are any changes in your Personal Data.
We will retain your Personal Data for as long as you use our Site and at least six years following that to comply with regulatory recordkeeping obligations we have.

7. Information that we may share

Personal Data we collect will not be disclosed to any third parties by us or our affiliates except in the following circumstances:

• We may disclose your Personal Data to third party service providers solely in the course of their provision of services to Bambucorn and will take reasonable precautions to ensure that these service providers are obliged to keep your Personal Data secure and confidential, in compliance with relevant legal requirements. Your Personal Data may be transferred outside the Kingdom of Bahrain (Bahrain) and if this is the case, we will ensure that the transfer is compliant with PDPL.

• We may disclose your Personal Data after you have explicitly consented to the proposed transfer, including but not limited to transfers to one or more of the following parties: (i) KYC and AML solutions providers, (ii) Custodian(s), (iii) Issuers and Sellers with whom you have signed an ISA(s) (as an investor), (iv) to our Auditors, (v)  suppliers and sub-contractors for the performance of any contract we enter into with them for you and (vi) entities within our Group for administrative purposes. 

• We may transfer your Personal Data after it has been determined that the transfer is necessary for the performance of a contract between yourself and us.

• We may transfer your Personal Data after it has been determined by us that the transfer is necessary for the conclusion or performance of a contract that is in your interest between a Controller (Bambucorn) and a Third Party.

• We may disclose your Personal Data to fulfil any legal or regulatory obligation we may have.

• In the event that we intend to enter into a major corporate transaction, such as a sale of control of the Site, we may disclose certain of your Personal Data to potential buyers, underwriters or advisors. If we do this, we will take reasonable precautions to ensure that the recipients of your Personal Data are obliged to keep it secure and confidential, in compliance with relevant legal requirements.

• We may disclose your Personal Data to an Expert to facilitate communication between yourself and the Expert. 

• We may disclose your Personal Data to third parties to conduct industry research. We will only do so if you have provided your consent for this purpose.

8. Security

All information provided to us by you or otherwise is stored on our secure servers. In addition, to help protect your Personal Data and to minimize the risk of it being accessed by unauthorized parties, our secure servers shall use industry standard Secure Socket Layer (SSL) and Transport Layer Security (TLS) technology when you submit information to through the Site. The fact that this Site uses industry standard SSL/TLS technology can be evidenced from the usage of the “https” protocol. 
If we have given you (or you have chosen) a password or account number, you are responsible for keeping this password and/or account number confidential. We ask you not to share these details with anyone and to inform us if you believe they have been compromised. 

9. Changes to this Privacy Policy

We may at our absolute discretion update this Privacy Policy from time to time. Please do review the Privacy Policy regularly for such updates. 

10. Contact

You may contact us regarding this Privacy Policy:

via email at 
contact@bambucorn.com
via post at
Office 31, Building 2342, Road 2830, Block 428
Al Seef
Kingdom of Bahrain.