Privacy Policy for TenFifty Capital

Effective Date: July 7, 2025

TenFifty Capital ("we," "our," or "us") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, and protect information when you visit our website, which is primarily used for marketing and informational purposes. As a company based in Spain and the Netherlands, we adhere to the principles of the General Data Protection Regulation (GDPR) (EU) 2016/679.

1. Who We Are

TenFifty Capital is a real estate debt and lending company. Our website is designed to provide information about our services and is not used for direct transactions or collecting personal data beyond what is outlined in this policy.

2. Information We Collect

We only collect information necessary for the operation and improvement of our website, as detailed below:

  • Analytics Data (via Google Analytics): We use Google Analytics to understand how visitors interact with our website. This service collects data such as:
    • Your IP address (anonymized)
    • Geographic location (country/city level)
    • Browser type and operating system
    • Pages visited on our site
    • Time spent on pages
    • Referral sources
    • Interaction with website elements (e.g., clicks)This data is primarily statistical and does not directly identify you. We have configured Google Analytics to anonymize IP addresses to enhance your privacy.
  • Essential Cookies: Our website uses essential cookies that are strictly necessary for the website to function correctly (e.g., for security or displaying content). These cookies do not collect any personal data.
  • Cookie Consent Management (via CookieHub): We use CookieHub to manage your cookie preferences. CookieHub uses cookies to remember your consent choices, ensuring that we only set cookies (like Google Analytics cookies) for which you have provided consent.

We do not collect any personal data through contact forms, newsletter sign-ups, or other direct input methods on this website.

3. How We Use Your Information

The information collected via Google Analytics is used solely for the following purposes:

  • Website Improvement: To understand how visitors use our website, identify popular content, and improve the user experience and navigation.
  • Marketing Effectiveness: To analyze the effectiveness of our marketing efforts by understanding website traffic and engagement.
  • Statistical Analysis: For aggregated statistical analysis to inform our business decisions.

We do not use the collected data for direct marketing, lead generation, or share it with third parties for their independent marketing purposes.

4. Legal Basis for Processing

Under the GDPR, our legal basis for processing the limited personal data collected via Google Analytics (e.g., anonymized IP addresses) is Legitimate Interest. Our legitimate interest is to understand website usage and improve our online presence for marketing and informational purposes, while respecting your privacy by anonymizing data and providing clear consent mechanisms. For the use of non-essential cookies (like those for Google Analytics), our legal basis is your Consent, which you provide or manage through our CookieHub banner.

5. Data Retention

We retain the personal data collected through Google Analytics for no longer than is necessary for the purposes for which it was collected. Google Analytics data is retained for [Insert Specific Google Analytics Retention Period, e.g., 26 months, 38 months] and is automatically deleted or anonymized by Google after this period. Information related to your cookie consent preferences managed by CookieHub is retained for a reasonable period to ensure your preferences are remembered.

6. Cookies

Our website uses cookies to function effectively and to gather anonymized analytics data. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site.

  • Essential Cookies: These cookies are necessary for the website to operate and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences.
  • Analytics Cookies: These cookies are set by Google Analytics and allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.

You have full control over your cookie preferences through our CookieHub consent banner. When you first visit our site, you will be presented with a banner allowing you to accept, decline, or customize your cookie settings. You can change your preferences at any time by clicking the cookie icon usually located in the corner of the website.

7. Your Data Protection Rights (GDPR)

Under the GDPR, you have the following rights regarding your personal data:

  • The Right to Be Informed: You have the right to be informed about the collection and use of your personal data. This Privacy Policy serves to fulfill that right.
  • The Right of Access: You have the right to request access to the personal data we hold about you.
  • The Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
  • The Right to Erasure ("Right to Be Forgotten"): You have the right to request the deletion of your personal data where there is no compelling reason for its continued processing.
  • The Right to Restrict Processing: You have the right to request that we limit the way we use your personal data in certain circumstances.
  • The Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
  • The Right to Object: You have the right to object to the processing of your personal data in certain circumstances, particularly where processing is based on legitimate interests.
  • Rights in Relation to Automated Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. (Note: Our website does not engage in such activities).

To exercise any of these rights, please contact us at:

Email: hfraser@tenfiftycapital.com

We will respond to your request within one month, as required by GDPR.

8. Data Security

We implement appropriate technical and organizational measures to protect the personal data we process from unauthorized access, alteration, disclosure, or destruction. While we strive to protect your personal data, no method of transmission over the Internet or method of electronic storage is 100% secure.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. Any updates will be posted on this page with a revised "Effective Date." We encourage you to review this Privacy Policy periodically.

10. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

TenFifty CapitalEmail: partnerships@tenfiftycapital.com