About This Website; Company Information
This website, www.scions.tech (the “Site”) is a website owned by Sigma Research and Consulting Company, a company with its mailing address at Langegracht 70, 2312NV Leiden, Netherlands (“Sigma Research and Consulting”, “us,” “our” or “we”).
SCIONS.tech and the Sigma Research and Consulting Company are not registered as broker-dealer or investment advisers. No investment recommendations or financial advice will be provided by us; any representations or information made on our site do not constitute and should not be construed as investment recommendations or advice.
With respect to Loan Participations and Syndicated Loans, the individual Borrower responsible for the Project is responsible for all information provided with respect to a project on the site.
With respect to any deal offerings (investing, buying, selling) that may be listed here, all deals are offered by the applicable issuer of such deals and all information included on this site is the responsibility of the same applicable issuer of such deals.
No steps has been taken by SCIONS.tech in order to verify the completeness, accuracy, or adequacy of any information. Neither SCIONS.tech nor any of its employees, agents, directors, or officers makes any warranty, implied or express, of any kind whatsoever regarding the completeness, accuracy, or adequacy of any information or the use of information on this site.
Information We Collect About You
Personal Data: Personal data, which is sometimes called “personally identifiable information” in the United States (“Personal Data”) is information that can be used to identify you as an individual, such as a name, online identifier, location data, or an identification number. In addition, it can include some aspects about your social, cultural, economic, mental, genetic, physiological, or physical identity which can assist others in eventually identifying who you are. Your personal data will be collected by SCIONS.tech when you use our site in different ways such as signing up for an account, sending us an email through our site, using our site to engage in a transaction, or completing applications or forms on our site. SCIONS.tech may also collect information which may be contained on server logs, such as your Internet protocol (“IP”) address.
The types of Personal Data that we collect through our Site may include, but are not limited to, your: (1) personal name; (2) physical address; (3) email address; (4) phone number; (5) Social Security Number; (6) date of birth; (7) business name; (8) business address; (9) information from an identity document such as a passport or driver’s license; (10) job title; (11) bank account information; (12) credit card information; (13) articles of incorporation; and (14) any other Personal Data you may voluntarily provide.
Furthermore, other data that we may collect and store in our log files may include, but may not be limited to, for example, date(s) and time(s) of visits to our Site, time spent viewing pages on our Site, frequency of visits to our Site, clickstream data operating system, cookies existing on your computer, device type used to visit our Site (desktop or mobile), browser type, and sites visited before arriving at our Site. This information will be collected through automated tracking technologies, some of which are discussed below. This automatically collected information may be combined with other information we collect about you. We do this to improve our site and to improve services we offer you.
Personal Data may be obtained from third party sources. Types and uses of such third party sources may include (but may not be limited to): (1) payment facilitation services; (2) services used for anti-money laundering screening; (3) services used to verify identity and backgrounds.
How We Collect Your Personal Data
Your personal data is collected when you voluntarily provide it through our Site. For example, when you complete forms on our Site, you provide us with some information. For instance your information is provided to us when you create your user account or submit comments, feedback, or inquiries to us by email.
Our site, our service providers, or our Affiliated Companies may also collect information about you using various automated technologies on our site such as the following:
- When you visit our site or register for our Site, you consent to our use of first-party and third-party cookies and other automated technologies that we or third parties may use to collect information from our Site.
- Web Beacons. Web Beacons are small electronic files which may be contained in some pages of our Site (web beacons are also referred to as single-pixel gifs, pixel tags, and clear gifs) that allow us, for example, to count users who have visited those pages of our Site and for other related website statistics (for example, recording the popularity of certain website content and verifying the integrity of server and system).
- Log File Data. Log files are reported automatically by your web browser. They may include information such as webpages viewed or visited, browser type and configuration, frequency and timing of clicks you make on webpages, and even your Internet protocol (“IP”) address. We can use this information to improve our website.
- Analytics. We may use service providers and analytics programs, such as Mixpanel and Google Analytics that are able to use first party cookies to report on your interactions with the Site. Mixpanel and Google Analytics collect information including, but not limited to, what pages you viewed on the Site, what website referred you to the Site, whether you have visited the Site before, and the time of each of your visits to the Site. You can also choose to opt-out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout or, with regard to Mixpanel’s automatic collection of data, by visiting https://mixpanel.com/optout.
The technologies that have been mentioned above are used in gathering demographic information about our user base as a whole, tracking users’ movements around our Site, administering our Site, and analyzing trends. Third-party companies may send us reports based on the use of these technologies on an individual as well as aggregated basis. We can use this data to improve our Site.
How We Use Information We Collect About You
The Personal Data and other information will be used by SCIONS.tech: (1) to market our Site or our affiliates’ services, products, and websites to you and other users of our Site; (2) analyze data in order to send more targeted messages to users of our Site; (3) to conduct research and analyze the research data to enhance and improve our Site, services, and products; (4) to enable our contractors and vendors to provide and help us in the analysis, troubleshooting, operation, and marketing of our Site and other services; (5) to fulfill service and product requests; (6) to deliver email messages like service announcements, customer service, newsletters, updates, and special offers; (7) to comply with and meet any regulatory requirements for the offer or sale of securities required by law; (8) to protect our Site or the users of our site; (9) to engage in any other lawful activities we believe are consistent with the foregoing; and (10) when required by law (for example, to comply with a subpoena or similar legal process), when we deem it necessary to protect against legal liability, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
We may provide or obtain any of the above services through third parties, which may necessitate sharing Personal Data with them. With regard to use of your information for marketing, none of the information is shared beyond Sigma Research and Consulting’ affiliates.
Certain Personal Data may be made available on our Site and may be made visible to other users of or visitors to our site. For instance your first name and last name initial will be shown on our Site if you invest in a securities offering on our Site. A feature may be provided on our Site that will enable you to opt-in to display your whole name along with social media handles, Site investment history, your location, and a short bio. Prospective borrowers seeking financing via our Syndicated Loan offerings will have to provide more extensive Personal Data on their offering page, such as the names of their directors and officers, their background and biographies that will be viewable by other users of our Site.
There may be a feature in our Site that with enabling it you can opt-in to display your whole name as well as social media handles a short bio, Site investment history, and your location. Prospective borrowers seeking financing via our Syndicated Loan offerings will have to provide more extensive Personal Data on their offering page, such as the names of their officers and directors, their biographies and background that will be viewable by other users of our Site.
Your personal information may be shared by SCIONS.tech with affiliated companies, for the lawful purposes set forth in this Policy, as necessary to provide services and products to you.
Individuals or third-party companies are employed or contracted by SCIONS.tech so that they can perform certain services or functions on its behalf. Examples of these services from such individuals, companies, or third parties may include, but may not be limited to, providing customer service, providing marketing assistance, analyzing data, disbursement of funds, escrow services, sending e-mail, payment storing and facilitation, electronic document signing, credit/financial/accredit verification, and ID verification. These third parties may have access to, and SCIONS.tech may share with these third parties, your information, including Personal Data needed to perform their services or functions for users of our Site. However, these third parties may not use your information for other purposes. To the extent that your Non-Personal Data or Personal Data is provided to such third parties, the information will be collected and used by the third parties only to perform their prescribed functions or services.
Transfer of Your Information
Transfers Relating to Our Own Corporate Transactions. There may be times that your information may have to be transferred by us to a buyer or other successors to our business in the event of a dissolution, reorganization, restructuring, divestiture, merger, or other transfer or sale of some or all of SCIONS.tech’s assets, whether as a going concern or as part of a liquidation, bankruptcy, or similar proceeding, in which Personal Data Information held by us about our Site users is among the assets transferred.
SCIONS.tech believes that it complies with the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. If there is any question or if you have any complaint regarding the participation of SCIONS.tech in the Swiss-US or EU-US Privacy Shield, please contact us at email@example.com. If there is any complaint regarding the Privacy Shield frameworks that SCIONS.tech cannot resolve directly, we have chosen to cooperate with a panel established by the European data protection authorities, or the relevant Data Protection Authority for resolving disputes. Please contact us if you’d like us to provide you with contact information for your Data Protection Authority. As it has been further explained in the Privacy Shield Principles, which you can find at https://www.privacyshield.org, binding arbitration is available to address residual complaints not resolved by other means.
Third Party Websites and Services
There may be times that we or our affiliates send you e-mail communications with general marketing information, despite the fact that none of your Personal Data is shared for marketing purposes beyond affiliates of SCIONS.tech. If it is in your preference not to receive such promotional or marketing e-mails, you may unsubscribe by emailing us at firstname.lastname@example.org, or you may unsubscribe via your account dashboard, or you may choose to stop receiving our marketing or newsletter emails by following the “unsubscribe” instructions included in these emails. However, even if you choose not to receive any of these emails, there are some types of emails that you cannot choose not to receive them such as emails regarding emails responding to specific inquiries from you, legal notices we may be required to give, or specific transactions you have participated in on our Site.
In addition, please note that at times we may need to send you e-mail communications which are transactional in nature and which you will not be able to opt-out of, such as payment confirmations, or termination or service announcements.
Accessing, Changing and Otherwise Controlling Your Personal Data
There are certain right for you about the data we process about you. This includes, among others, the right to export, erase, and rectify your Personal Data, to object to the processing of your personal data, and to access your Personal Data.
Based on your consent, we process your Personal Data and concerning this process, you have the right to withdraw your consent. You may withdraw your consent by emailing email@example.com with “CONSENT WITHDRAWN” in the subject line.
If we process your personal data based on the legitimate interests of our organization or the legitimate interests of third parties, you have the right to raise an objection to such processing by contacting us at firstname.lastname@example.org.
You will be able to choose to remove your account and any of your Personal Data that is associated with that account. However, we will reserve the right to retain and use your Personal Data as necessary to comply with our legal obligations, enforce our legal agreements, resolve disputes, and provide our services. For example, we may need to retain archival copies of your information for compliance or legal purposes even after you have requested the deletion of your information.
Your personal data will generally be retained only for as long as necessary to accomplish the purposes for which we processed the data, which may include delivering the services to you for which you accessed our website.
With regard to certain types of Personal Data, you have provided consent for a retention period of longer duration than the period we would be required to preserve it in order to complete the processing for the purposes you intended. In that case, we will retain the data in accordance with your consent.
If the type of an item of Personal Data is particularly sensitive, we will shorten the retention time period that we would otherwise normally observe.
In some cases, you have provided Personal Data with the manifested intention that it be retained until you yourself initiate its removal. Nevertheless, in this case and other cases, we may be forced to delete the data earlier than you wish if, for example, you exceed the limit on the quantity of data that we can store in your account.
Automated controls may be provided by our website which will give you the freedom to delete Personal Data any time you wish. When such controls are absent, we are likely to prescribe a shortened data retention period.
If we adopt a data retention program or schedule prescribing various retention periods for different types of Personal Data, we will post it on our website.
There are certain exceptions to our policy of retaining your Personal Data for only as long as is necessary to accomplish the purposes for which you wanted to have the data processed in the first place. Your Personal Data will be retained for as long as is necessary to comply with our legal obligations, including contractual obligations, to serve our legitimate interests, and to pursue our remedies and rights and defend ourselves in litigation and other proceedings with governmental authorities, business entities, and individuals. The law may require us to preserve information, including Personal Data, that is relevant to such proceedings for a prescribed period of time. Proper institutional and technical measures will be taken by us to safeguard your freedoms and rights as required by the GDPR (General Data Protection Regulation).
Depending upon your use of various features of our website and the services we provide through our website, the nature of our interactions with you, the country or other jurisdiction in question, and the data type, the periods for which we are required to retain data can vary. We may be subject to mandatory data removal laws or data retention laws based on applicable rules of court or arbitration procedure, administrative order, data required to be retained in adversarial proceedings pursuant to a court order, government orders to preserve data in connection with an investigation, or content.
Social Media Widgets
We use reasonable efforts to secure access to Personal Data in our possession but will not be liable for any failure to safeguard such information, whether inadvertent or otherwise. Information you provide to us is encrypted and stored securely on private cloud servers through third-party service providers that we use. We also take commercially reasonable efforts to store as little sensitive information as possible.
We are required to notify you without undue delay in the event of a data breach on our part causing high risk to data subjects. The notification must include at least: any measures taken by us to mitigate or remedy the breach; the likely consequences of the data breach; and the name and contact details of the DPO (or other relevant point of contact). However, we may be exempt from this requirement if: the notification requires disproportionate effort (in which case we must issue a public notice of the breach); we have taken measures to protect against the harm (e.g., suspending affected accounts); or the risk of harm is remote because the affected data are protected (e.g., through strong encryption).
Although we and our service providers, who have informed us that they also use reasonable efforts to secure Personal Data, take commercially reasonable efforts to keep secure any Personal Data, there is no guarantee that any communication over the public Internet is 100% secure at all times. Therefore, neither we nor our service providers shall be held liable for the failure to safeguard Personal Data, whether inadvertent or otherwise, except where you, as a data subject, prove that you have suffered material or non-material damage as a result of our infringement of the GDPR, in which event you shall have the right to receive compensation from us, in our capacity as data controller or processor, for the damage suffered.
In addition, it is important for you to take appropriate measures to make sure your computer and your password are protected against unauthorized access. Always make sure to log off any computer or device you use to access your account on our Site after you have finished.
The SCIONS.tech Site is not intended for use by children. No one under eighteen (18) years of age is allowed to receive our email distributions, provide any Personal Data, or use our Site. We do not knowingly solicit or collect Personal Data from children under the age of thirteen (13) or anyone under eighteen years of age. If you believe that anyone under these ages has disclosed Personal Data to SCIONS.tech, please report this to us immediately by emailing us at email@example.com.
Your Rights Regarding Any Complaints You May Have About Our Protection of Your Personal Data.