Effective Date: September 2024

Last Updated: June 2025

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Introduction

This privacy policy describes how White Glove Investments, Inc., a Delaware corporation headquartered at 347 FIFTH AVE., SUITE 1402-280 NEW YORK, NY 10016, and its affiliates and subsidiaries (collectively “WGI”, “we”, “us”, or “our”) collect, use, share, and protect personal data across our products and services.

We are committed to protecting your personal data and processing it in compliance with:
- General Data Protection Regulation (GDPR)
- UK Data Protection Act
- California Consumer Privacy Act (CCPA/CPRA)
- Other applicable U.S. state privacy laws

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Policy Overview

- What data do we collect?
- How is data collected?
- How and why do we use personal data?
- Legal bases for processing (GDPR)
- Who do we share your data with?
- Transfers outside the EEA & UK
- Use of cookies and tracking technologies
- Retention of data
- Your rights (EU/UK and U.S.)
- Children’s privacy
- California-specific rights (CCPA/CPRA)
- Accessibility
- How to contact us
- Updates to this policy

 

What Information Do We Collect?

We may collect the following categories of personal data:
- Identifiers: Name, title, company, business email, phone number, LinkedIn URL, business address, WeChat ID (if applicable)
- Internet activity: IP address, browser/device information, page views, interaction logs
- Professional or employment-related information
- Geolocation (approximate, via IP address)
- Sensitive personal data: We do not knowingly collect sensitive data as defined by GDPR or CPRA unless explicitly stated

 

How Is Your Data Collected?

We collect data through:
- Direct interactions (e.g., email, phone, chat, events)
- Public sources (e.g., LinkedIn, websites, filings)
- Contributions from data contributors
- Website use (cookies, analytics)
- Registration or subscription to products or newsletters

 

Third-Party Authentication

If you choose to register or log into our services using a third-party account (such as LinkedIn or Google), we may receive limited information as permitted by your settings with that third-party provider. This may include your name, email address, profile picture, and public profile URL.

We use this information solely to authenticate your identity, create your account, and provide access to our services. We do not post content to your third-party accounts without your permission.

 

How and Why Do We Use Your Data?

We use your data for the following purposes:
- To provide, personalize, and improve services
- To display verified contact details to subscribers
- To communicate relevant insights or updates
- To fulfill contractual obligations
- To comply with legal requirements
- To detect misuse or fraud
- To improve our website and offerings

 

Legal Bases for Processing (GDPR)

- Legitimate Interests – research, data services, analytics
- Consent – marketing communications, displaying mobile/WeChat ID
- Contract – provision of services to subscribers or contributors
- Legal Obligation – for accounting, tax, or legal compliance

 

Who Do We Share Your Data With?

We may share data with:
- Subscribers to our services
- Partners providing surveys or analytics
- Cloud hosting and infrastructure providers (U.S. & EU)
- Billing/payment processors (PCI-compliant)
- Debt collection agencies
- Legal and regulatory authorities if required

We do not sell personal data. Some data may be “shared” under CPRA definitions.

 

International Data Transfers

Where data is transferred outside the EEA or UK, WGI relies on:
- Standard Contractual Clauses (SCCs)
- UK Addendum to SCCs
- Contractual safeguards with processors and partners

This includes transfers to:
- Offices in Singapore, London, San Francisco, Hong Kong
- Outsourced teams in the Philippines, China, and India
- U.S.-based cloud, analytics, and billing providers

 

Cookies & Tracking Technologies

We use cookies and similar tools for:
- Site functionality and personalization
- Analytics and performance tracking
- Email engagement (e.g., open/click tracking)

You can manage cookie preferences through your browser or our website banner (where applicable).

 

Data Retention

We retain data based on:
- Its original purpose and usage
- Contractual or legal requirements
- Security, analytics, and operational needs

Examples:
- Billing records: 7 years
- Access logs: 28 days
- Page view data: lifetime of the product
- Backups: 12 months
- CCTV: 12 months

 

Your Rights Under GDPR & U.S. Law

You have the right to:
- Access and receive a copy of your data
- Correct inaccurate or outdated data
- Delete your data in certain cases
- Object to or restrict processing
- Withdraw consent at any time
- Receive your data in a portable format
- Lodge a complaint with a data protection authority
- Opt-out of data “sharing” under CPRA
- Limit use of sensitive personal information (if collected)

To exercise these rights, email: info@WGI.com

We will respond within legally required timeframes and may request verification of your identity.

 

California Privacy Notice (CCPA/CPRA)

If you are a California resident, you may:
- Request to know what personal data we collect or share
- Request deletion of personal data
- Opt-out of the sale or sharing of personal data
- Correct inaccurate data
- Limit use/disclosure of sensitive personal information
- Not be discriminated against for exercising these rights

WGI does not sell personal data.
To opt-out of sharing, email: privacy@wgi.com with the subject line “Do Not Sell or Share My Personal Information”.

 

Children’s Privacy

WGI’s services are intended for business professionals.
We do not knowingly collect data from children under 16.
If such data is discovered, it will be promptly deleted.

 

Accessibility Statement

If you require this privacy policy in an alternative format due to a disability, please contact: info@WGI.com

 

How to Contact Us

Email: info@WGI.com
Postal Address: WGI CORPORATION, 347 FIFTH AVE., SUITE 1402-280 NEW YORK, NY 10016, USA

 

Updates to This Policy

We may update this policy from time to time.
The latest version will always be posted here.
If significant changes are made, we will notify you directly or via email.

 

Data Protection Officer (DPO) & EU Representative

As we do not currently have an office in the EU/EEA or UK but monitor or process personal data of EU/UK residents, WGI is in the process of appointing:
- An EU Representative under Article 27 of the GDPR
- A Data Protection Officer (DPO) to oversee compliance and handle data subject requests

If you are a data protection service provider or DPO advisor, you may contact us via info@WGI.com.

 

Publicly Available Profiles

WGI CORPORATION curates professional profiles based on publicly available sources, such as company websites, regulatory filings, industry events, and LinkedIn. This information includes professional name, role, company, public LinkedIn URL, and professional email address (if available).

These profiles are displayed to provide accurate, up-to-date intelligence to our subscribers and platform members. Individuals may request to update, remove, or opt out of having their profiles displayed by contacting privacy@wgi.com.

We do not collect personal or private (non-business) emails, passwords, or sensitive information from public sources.

 

Accredited Investor Self-Certification

Accredited investors who participate in fundraising activities on WGI CORPORATION's platform must first complete a self-certification process. This ensures that all interactions comply with applicable securities laws and regulations. The certification form is built into the platform onboarding process and is required before any fundraising or investment activity is visible or accessible

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