Privacy Policy

1. Introduction

ACFL Capital S.A. (“ACFL Capital”, “we”, “our”, or “us”) is committed to protecting the privacy and personal data of visitors, clients, and counterparties. This Privacy Policy explains how we collect, use, store, disclose, and protect personal data in accordance with applicable Swiss data protection laws, the EU General Data Protection Regulation (GDPR), and other relevant international standards.

By accessing or using our website, you acknowledge and agree to the practices described in this Privacy Policy.

2. Information We Collect

We may collect the following categories of information:

Personal Identification Information: Name, title, company, email address, phone number
Corporate Information: Company details, registration numbers, jurisdictions of operation
Transaction Information: Project summaries, transaction size, sector, geographic focus
Compliance Information: KYC/AML-related data where required
Technical Data: IP address, browser type, device information, cookies, and usage data

We only collect information that is necessary for legitimate business, compliance, or operational purposes.

3. Purpose of Data Processing

Personal data is processed for the following purposes:

Responding to inquiries and engagement requests
Conducting onboarding, underwriting, and compliance reviews
Fulfilling legal, regulatory, and contractual obligations
Improving website functionality and user experience
Preventing fraud, abuse, or unauthorized activity

4. Legal Basis for Processing

We process personal data based on one or more of the following legal grounds:

Consent provided by the data subject
Performance of a contract or pre-contractual measures
Compliance with legal or regulatory obligations
Legitimate business interests, provided they do not override data subject rights

5. Data Sharing & Disclosure

ACFL Capital does not sell personal data. Data may be shared only with:

Independent underwriters, legal advisors, insurers, and compliance providers
Regulatory authorities or law enforcement when legally required
Professional service providers under confidentiality obligations

All third parties are required to maintain appropriate data protection safeguards.

6. Data Retention

Personal data is retained only for as long as necessary to fulfill the purposes outlined in this policy or to comply with legal and regulatory requirements.

7. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or disclosure.

8. Your Rights

Depending on your jurisdiction, you may have the right to:

Access your personal data
Request correction or deletion
Restrict or object to processing
Withdraw consent at any time

Requests can be submitted through our Contact page.

9. Updates to This Policy

ACFL Capital reserves the right to update this Privacy Policy at any time. Changes will be posted on this page.are

Suggested text: Our website address is: https://acflcapital.com.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where your data is sent

Visitor comments may be checked through an automated spam detection service.