Privacy Policy

We Respect Your Privacy

We greatly value the trust and confidence you place in us, and we are committed to protecting your personal data. This Privacy Policy describes how we collect, process, use, share and secure the personal information you provide. It also describes your choices regarding use, access, and correction of your personal information.

Personal Data

This policy applies to personal data we may collect, process, and handle. For purposes of this statement, “personal data” means information that:

• is about, or pertains to, a specific individual; and
• can be linked either directly or indirectly to that individual.

Generally speaking, we collect, and process personal data as follows:

• from employees and independent contractors in the context of the employment or contractor relationship,
• from clients who wish to engage in advisory services or private placement securities transactions, and
• from customers and issuers (parties participating in securities transactions) as necessary to effect transactions and as required by regulatory agency or legal requirements.

Principles Protecting Individuals’ Privacy Notice and Choice

We collect personal data from individuals as follows:

• We notify individuals about the personal data we collect from them, how we use it and how to contact us with privacy concerns. All personal data is collected and processed with the express and informed consent of the relevant individuals or is collected and processed pursuant to mandatory legal requirements, including but not limited to those imposed by FINRA and the SEC.
• We provide such notice through this policy, our engagement letters or other similar documents, instructions on personal data collection forms, and direct communication with individuals from whom we collect personal data.
• Consent for personal data to be collected, used, and/or disclosed in certain ways (including opt-in consent for sensitive data) may be required in order for an individual to obtain or use our services. Such consent is provided through our engagement letters, employment agreements, customer identification forms, subscription agreements and other similar documents.

Disclosures and Transfers

We do not disclose an individual’s personal data to third parties, except when one or more of the following conditions is true:

• We have the individual’s permission to make the disclosure.
• The disclosure is required by our broker-dealer firm Zenya Capital Services*, in order to effect a private placement securities transaction or supervise the business activities of the firm’s registered representatives or foreign associated persons.
• The disclosure is required by lawful request by public authorities, including to meet national security, regulatory agency or law enforcement requirements.
• The disclosure is required by law or mandatory professional standards.
• The disclosure is reasonably related to the sale or other disposition of all or part of our business.
• The information in question is publicly available.
• The disclosure is reasonably necessary for the establishment of legal claims.
• The disclosure is to persons or entities providing services on our or the individual’s behalf (each a “transferee”), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question, is subject to law providing an adequate level of privacy protection or has agreed to provide an adequate level of privacy protection.
• We may supply personal data to a transferee for the purpose of verifying identification or suitability for customers and issuers.
• We may transfer personal data from one jurisdiction to another. Privacy laws vary by jurisdiction, and some may provide less or different legal protection than others.

* All securities are offered through Zenya Capital Services ZCS, member FINRA, SIPC. If you do not wish to provide all of the information requested on ZCS’ Customer Identification Form, or if your identity cannot be adequately verified in accordance with federal requirements, ZCS reserves the right to refuse your participation in the transaction. You can review ZCS’ Privacy Policy.

Data, Security, Integrity and Access

We employ various physical, electronic, and managerial measures, including education and training of our personnel, designed to reasonably protect personal information from loss, misuse or unauthorized access, disclosure, alteration or destruction. Personal data collected or displayed through a website is protected in transit by standard encryption processes. However, we cannot guarantee the security of information on or transmitted via the Internet.

We process personal data only for the limited and specific purpose for which it was originally collected or authorized by the individual. To the extent necessary for such purposes, we take reasonable steps so that personal data is accurate, complete, current, and otherwise reliable with regard to its intended use.

An individual has the right to access personal data we hold about them. An individual may contact us using the information below to correct, amend, or delete information where it is inaccurate. The individual will need to provide sufficient identifying information, such as name, address, and birth date. We may request additional identifying information as a security precaution such as possibly a national identifier (e.g. a Social Security number). In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or where the rights of persons other than the individual would be violated. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal information.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements.

Data Rights

Your rights under relevant data protection laws are complex. We have attempted to summarize your rights herein, but not all details can be included in these summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

You have the right to consent to whether we collect any personal data from you, and whether or not we process your personal data. Where we do process or share personal data, you have the right to know the purposes of the processing, the categories of personal data concerned, and any recipients of your personal data.

You have the right to have any inaccurate personal data about you corrected and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

To the extent not inconsistent with our legal and regulatory obligations, you may have the right to the erasure of your personal data.

You may have the right to restrict or object to the processing of your personal data under certain circumstances, subject to external legal and regulatory requirements. If you object, we will cease to process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us via email directed to Capital@ZenyaCapital.com

Accountability and Enforcement

You may file a complaint in connection with our processing of your personal data using the contact information below. We will take appropriate steps to address any adverse effects and to promote future compliance. Personnel who violate our privacy policies will be subject to disciplinary action or termination.

Amendment

We may amend this policy from time to time by posting a revised policy on this website. If we amend the policy, the new policy will apply to personal data previously collected only insofar as the rights of the individual affected are not reduced.

Contact Information

For further information, questions, access requests, or any other issues, please contact:

Name: Bobby Zapp
Title: Administrative Assistant
Company: Zenya Capital
Mailing address: 405 magnolia Road Pemberton New Jersey 08068
Email: Invest@ZenyaCapital.com
Phone number: (609) 248-5375

 

FORM PRIVACY POLICY

This Privacy Policy specifies the personal information that we ask you to provide and how we treat this information. This Privacy Policy is part of our Terms of Use, and all the terms and conditions set forth in the Terms of Use also apply to this Privacy Policy. Capitalized terms that are not otherwise defined in this Privacy Policy have the meanings given to them in the Terms of Use.

IF YOU DO NOT UNDERSTAND OR DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY PLEASE DO NOT USE THE SITE

YOUR CONSENT

You will be deemed to have consented to the terms of this Privacy Policy by using the Site in any way, even just browsing. We may also ask you to indicate your consent more formally by checking a box or otherwise taking an affirmative action.

CHANGES TO PRIVACY POLICY

We might change this Privacy Policy from time to time. If you have consented merely by using the Site, then we will not necessarily notify you of the changes. If you have consented more formally, as described above, then the changes will not become effective until we have asked you for, and obtained, your consent.

PERSONAL INFORMATION WE COLLECT

We collect a variety of personal information to operate the Site and provide the Service, including:

• Your name, address, phone number, email address, birth date, and other personal information.
• Financial information, including your social security number, income, and net worth.
• Copies of your tax returns, brokerage statements, W-2 forms, and other financial documents.
• Your username and password.
• Information to confirm your identity, such as a completed electronic check transaction or a credit report.
• Your W-9 form.
• Information to confirm your place of residence.
• Information about your use of the Site.
• Information about your computer configuration.
• Information to confirm your relationship with other parties associated with the Site.
• Information about your bank accounts or other sources of payment.
• Your IP address.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information to:

• Verify that you are permitted to use and invest through the Site.
• Keep track of your investments.
• Guard against fraud.
• Comply with applicable law.
• Answer your questions.
• Protect our rights.
• Send to third parties at your request.
• Process your transactions at the Site.
• Determine whether your computer information is compatible with the Site.
• Keep track of your use of the Site.
• Send you information about your investments.
• Notify you of other possible investments in which you might have an interest.
• Analyze the use of the Site.
• Improve the Site.
• Send you information about the Site.
• Send you materials about us.
• Use for other purposes we disclose to you.

WHAT WE PROVIDE TO THIRD PARTIES

We do not provide any third party with any of your personal information except in these situations:

• We use third parties to perform services for the Site, such as hosting services, electronic signature providers, electronic payment service providers, and services that verify the qualification of investors. Each of these third parties will need some of your personal and/or financial information to perform their services.
• If you invest, we will identify you on tax returns and other government forms.
• We will provide information if we believe we are required to do so by law.
• If our company is sold, all information will be transferred to our successor.
• If you choose to participate in discussions or messages boards at the Site, other users will be able to see your name (but not any other personal information) and any other information you voluntarily provide to be seen.

We do not provide any of your personal information to third parties for marketing purposes.

OUR AFFILIATES

We may provide information to one or more of our affiliates, meaning a company that we control or that is under common control with us. All of our affiliates will also be bound by the terms of this Privacy Policy.

NOTIFICATIONS AND COMMUNICATIONS FROM US

We will send you email notifications from time to time. For example, we may send you emails:

• To confirm your registration.
• To provide you with legal notices.
• To notify you of new investment opportunities.
• When the online profile you created is changed.
• To ask you to participate in surveys or otherwise provide feedback.
• To confirm your investment in a project.
• To ask you for information.

You may also receive emails from third party providers.

MODIFYING AND DELETING INFORMATION

To modify or delete your personal information, please log in and update your profile. We may retain certain information as required by law or for necessary business purposes.

HOW WE PROTECT YOUR INFORMATION

We have put in place systems designed to protect your personal information, including:

• We employ a secure channel, using Secure Sockets Layer encryption, the standard for secure Internet network connections, to protect information exchanged over the Internet between your web browser and our servers.
• Our employees and agents are required to abide by this Privacy Policy.
• We use automated tools to monitor network traffic to identify unauthorized attempts to upload information, change information, or otherwise seek to gain unauthorized entry into our systems.
• We take additional steps to protect especially sensitive information.
• In general, we use the same level of data encryption that is used by banks.

Nevertheless, no security system is perfect. We cannot guarantee that your personal information will remain private.

COOKIES, ETC.

A cookie is a small amount of data sent to your browser from our computer. We use cookies to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. You may set your browser so that it does not accept cookies, although this would affect the usability of the Site.

We or our service providers (such as Google Analytics) may collect data related to your use of the Service, including which of our pages you access, the frequency of such access, and your product and service preferences. This data collection may be accomplished by using cookies, web beacons, page tags or similar electronic tools. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you visit the Site. Web surfing data and similar information may be used for administrative purposes, to assess the usage, value, and performance of our online products and services, and to improve your experience with the Service. As with cookies, the web surfing information collected is aggregated, anonymous “click stream” and transactional data, and is not associated with any users as individuals.

If you would prefer not to see advertising based on your personal preferences, you can change your personal settings in Google (look for “Ad Settings”) or visit the website of the Network Advertising Initiative located at:

http://www.networkadvertising.org/choices/#completed/

THIRD PARTY SITES

You might navigate to websites maintained by third parties by clicking on a link from our Site, including through a banner advertisement. Once you leave our Site, the terms of this Privacy Policy no longer apply, and we have no control over the collection or use of personal information you provide to such websites.

NOTICE OF PRIVACY RIGHTS TO CALIFORNIA RESIDENTS

California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (the “California Act”) and the California Business and Professions Code. The California Act requires us to inform you, at your request, of (1) the categories of personal information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. The California Act further requires us to allow you to control who you do not want us to share that information with. To obtain this information, please send a request by email or standard mail. When contacting us, please indicate your name, address, email address, and what personal information you do not want us to share with marketing partners. The request should be sent to the attention of our legal department and labeled “California Customer Choice Notice.” Please allow 30 days for a response. There is no charge.

COMPLAINTS AND SUGGESTIONS

Please send your privacy-related complaints and suggestions to: Invest@ZenyaCapital.com/
You can also send complaints to regulators. Please contact your state´s consumer protection authority.

Investing involves risk, including loss of principal. Past performance does not guarantee or indicate future results. Any historical returns, expected returns, or probability projections may not reflect actual future performance. While the data we use from third parties is believed to be reliable, we cannot ensure the accuracy or completeness of data provided by investors or other third parties.

Neither Zenya Capital Investments nor any of its affiliates provide tax advice and do not represent in any manner that the outcomes described herein will result in any particular tax consequence. Offers to sell, or solicitations of offers to buy, any security can only be made through official offering documents that contain important information about investment objectives, risks, fees and expenses. Prospective investors should consult with a tax or legal adviser before making any investment decision.

Different rules apply to accredited investors and non-natural persons. Before making any representation that your investment does  not exceed applicable thresholds, we encourage you to review Rule 251(d)(2)(i)(C) of Regulation A. For general information on investing, we encourage you to refer to www.investor.gov.