Legal

Privacy Policy

Effective Date: 1 January 2025. This policy describes how Innekto Incorporated and its affiliates collect, use, disclose, and safeguard information obtained through this website and in the course of our institutional business relationships.

1. Scope & Application

Who This Policy Applies To

This Privacy Policy applies to all personal data processed by Innekto Incorporated and its affiliated entities (collectively, “Innekto,” “we,” “us,” or “our”) in connection with use of this website (the “Site”) and in the ordinary course of our institutional business operations.

Innekto operates exclusively with institutional counterparties, qualified professional investors, and corporate clients. This Site is not directed at retail investors or members of the general public. Individuals who access this Site in a personal capacity do so at their own initiative and are responsible for ensuring compliance with applicable local laws.

By accessing or using this Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with its terms, please discontinue use of the Site immediately.

2. Information We Collect

Categories of Personal Data

We collect personal data through several channels, including directly from you when you submit an enquiry form, correspond with us by email, or engage us for services. The categories of personal data we may collect include:

Identity & Contact Data

Full name, job title, employing organisation, business email address, and telephone number submitted via the enquiry form or correspondence.

Professional & Institutional Data

Information regarding the organisation you represent, its jurisdiction, the nature of your enquiry, and your professional capacity as an institutional counterparty or qualified investor.

Technical & Usage Data

IP address, browser type and version, operating system, referring URLs, pages visited, time spent on pages, and other diagnostic data collected automatically when you access the Site.

Communication Records

Records of correspondence, meeting notes, and communication logs generated in the course of responding to your enquiries or conducting business engagements.

Cookie & Tracking Data

Data collected via cookies and similar technologies as described in Section 5 below.

3. How We Use Your Information

Purposes of Processing

Innekto processes personal data only for specified, explicit, and legitimate purposes. We do not use personal data in any manner incompatible with these purposes. The primary purposes for which we process your data include:

  • Responding to and managing institutional enquiries submitted through the Site
  • Evaluating eligibility for, and conducting due diligence in connection with, potential engagements
  • Performing contractual obligations under mandates, advisory agreements, and service engagements
  • Maintaining records of communications and business relationships as required by applicable law or regulation
  • Ensuring the security, performance, and integrity of the Site and our technology infrastructure
  • Complying with applicable anti-money laundering, know-your-client, and other regulatory obligations
  • Managing legal disputes, claims, or regulatory investigations in which we are involved
  • Sending transactional communications directly related to an active or potential engagement

Innekto does not sell personal data to third parties, nor does it use personal data for direct marketing to individuals in their personal capacity.

4. Legal Basis for Processing

Grounds Under Applicable Law

To the extent applicable data protection legislation (including the EU General Data Protection Regulation, UK GDPR, and comparable frameworks) applies to our processing activities, Innekto processes personal data on the following legal bases:

Contractual Necessity: Processing required to enter into or perform a contract with the organisation you represent, including responding to pre-contractual enquiries and executing engagement mandates.

Legitimate Interests: Processing necessary for our legitimate business interests, including Site security and performance monitoring, fraud prevention, business development activities directed at institutional entities, and the maintenance of engagement records — provided such interests are not overridden by your rights.

Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including KYC/AML requirements, financial record-keeping mandates, and regulatory reporting.

Consent: Where we rely on consent as a legal basis, you may withdraw such consent at any time by contacting us at the address set out in Section 10 below, without prejudice to the lawfulness of processing conducted prior to withdrawal.

5. Cookies & Tracking Technologies

Use of Cookies on This Site

This Site may use cookies, web beacons, and similar tracking technologies to facilitate Site functionality and collect usage analytics. Cookies are small data files stored on your device that help us understand how visitors interact with our Site.

Strictly Necessary Cookies are required for the Site to function correctly and cannot be disabled without materially impairing your ability to use the Site. These include session management and security tokens.

Analytics Cookies allow us to measure and improve the performance of the Site by collecting anonymous data on visitor behaviour, including pages visited, time on site, and referral sources. This data is processed in aggregate form and is not used to identify individual visitors.

Innekto does not use advertising cookies, retargeting pixels, or cross-site tracking technologies. We do not share cookie data with advertising networks or data brokers. You may configure your browser to block or delete cookies; however, doing so may impair certain Site functions.

6. Disclosure of Personal Data

Third-Party Sharing

Innekto does not sell, rent, or trade personal data. We may disclose personal data to third parties only in the following limited circumstances:

Service Providers: We engage third-party service providers to support our business operations (including cloud infrastructure, cybersecurity, legal counsel, compliance, and accounting firms). Such providers access personal data only to the extent necessary to perform services on our behalf and are contractually obligated to maintain appropriate data security standards.

Professional Advisors: In connection with an active mandate or engagement, we may share relevant information with co-advisors, legal counsel, or counterparties as necessary to complete the transaction, subject to appropriate confidentiality undertakings.

Regulatory Authorities: We may disclose personal data to competent regulatory, governmental, or law enforcement authorities where required or permitted by applicable law, or in response to valid legal process.

Corporate Transactions: In the event of a merger, acquisition, or restructuring of Innekto, personal data held by us may be transferred to successor entities, subject to equivalent privacy protections.

7. International Data Transfers

Cross-Border Processing

Innekto operates globally, with offices in New York, Houston, and Dubai. Personal data collected through this Site or in the course of our business operations may be transferred to, and processed in, jurisdictions other than the one in which you are located, including the United States and the United Arab Emirates.

Where we transfer personal data from the European Economic Area, the United Kingdom, or other jurisdictions with data transfer restrictions to countries not recognised as providing an equivalent level of protection, we implement appropriate safeguards including Standard Contractual Clauses approved by the relevant supervisory authority or other lawful transfer mechanisms.

By engaging with this Site or submitting an enquiry, you acknowledge that your personal data may be processed in these jurisdictions and that the data protection laws of those jurisdictions may differ from those in your country of residence.

8. Data Security

Protection of Your Information

Innekto maintains technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures are commensurate with the sensitivity of the data processed and are reviewed periodically in light of evolving threats and best practices.

Transmission of data over the internet is inherently insecure, and Innekto cannot guarantee the security of data transmitted to or from the Site. You assume responsibility for maintaining the confidentiality of any credentials or contact information you provide. In the event of a data breach affecting your rights and freedoms, we will notify affected individuals and relevant supervisory authorities as required by applicable law.

9. Retention of Personal Data

How Long We Keep Your Data

Innekto retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law, regulatory obligation, or legitimate business necessity. Specifically:

Enquiry data submitted through the Site that does not proceed to an engagement is retained for a period of no longer than twelve (12) months, after which it is securely deleted or anonymised unless we are required to retain it for compliance purposes.

Data relating to completed mandates and engagements is retained for a minimum of seven (7) years following completion of the engagement, consistent with applicable financial record-keeping requirements and statutes of limitation.

Technical and usage data is retained for no longer than twelve (12) months and is processed in aggregate where possible.

10. Your Rights

Data Subject Rights

Depending on your jurisdiction of residence, you may have rights with respect to the personal data we hold about you, including the right to:

  • Access the personal data we hold about you and receive a copy in a portable format
  • Request correction of inaccurate or incomplete personal data
  • Request erasure of personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations
  • Object to or restrict processing based on our legitimate interests
  • Withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing
  • Lodge a complaint with a competent supervisory authority in your jurisdiction

To exercise any of these rights, or for any privacy-related enquiries, please contact our Privacy function at privacy@innekto.com. We will respond to verified requests within the timeframe required by applicable law (typically 30 days, subject to extension where permitted).

Note that certain rights may be limited where processing is required to comply with legal obligations, protect the rights of others, or fulfil a contract with the organisation you represent.

11. Updates to This Policy

Policy Amendments

Innekto reserves the right to amend this Privacy Policy at any time. The effective date at the top of this page will be updated to reflect any material changes. We encourage users who engage regularly with this Site to review this Policy periodically. Continued use of the Site following publication of an amended Policy constitutes acceptance of the amended terms.

For questions regarding this Privacy Policy or Innekto's data handling practices, please contact: privacy@innekto.com or write to Innekto Incorporated, 100 W 57th Street, New York, NY 10019, United States.

Disclaimer

The information presented on this page is intended for institutional counterparties and professional investors only. All references to target returns, yield strategies, and projected outcomes represent forward-looking estimates subject to material market, credit, liquidity, and operational risks. Past performance is not indicative of future results. Nothing herein constitutes an offer to buy or sell securities or investment products.