Last Updated: 27.02.2026.
Introduction
Vicman's Capital SIA (Registration No. 50203384331) ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard information when you visit our website or interact with our services.
This policy applies to individuals who:
- Visit our website (vicmanscapital.com)
- Inquire about investment opportunities
- Are current investors in our fund
- Attend our events or receive our communications
Legal Basis
We process personal data in accordance with:
- General Data Protection Regulation (GDPR) (EU) 2016/679
- The Personal Data Processing Law of the Republic of Latvia
- Latvijas Banka regulations governing Alternative Investment Fund Managers (AIFP)
Information We Collect
Information You Provide Directly:
- Contact information (name, email, phone number)
- Investment inquiry details (investment amount, investment goals)
- Identity verification documents (for investor onboarding)
- Financial information (for investor suitability assessment)
- Communication preferences
Information Collected Automatically:
- Website usage data (pages visited, time spent, referring sites)
- Device information (browser type, IP address, operating system)
- Cookies and similar tracking technologies
Information from Third Parties:
- Identity verification from KYC/AML service providers
- Credit reference agencies (where required for investor suitability)
- Regulatory databases (as required by law)
How We Use Your Information
We process personal data for the following purposes:
Investor Relations:
- Processing investment inquiries
- Conducting investor suitability assessments
- Managing investor accounts and communications
- Distributing quarterly reports and fund updates
- Facilitating investor meetings and events
Legal and Regulatory Compliance:
- Know Your Customer (KYC) verification
- Anti-Money Laundering (AML) checks
- Compliance with Latvijas Banka reporting requirements
- Tax reporting obligations
- Responding to legal requests or court orders
Business Operations:
- Website functionality and security
- Responding to inquiries and customer service
- Improving our services and website experience
- Internal record-keeping and administration
Marketing (with your consent):
- Sending fund performance updates
- Invitations to investor events
- Industry insights and market commentary
Legal Basis for Processing
We process your personal data under the following legal grounds:
- Contractual necessity: To fulfill our obligations to current investors
- Legal obligation: To comply with AML/KYC, tax, and regulatory requirements
- Legitimate interests: To operate our business, communicate with prospective investors, and improve our services
- Consent: For marketing communications (you may withdraw consent at any time)
Data Sharing and Disclosure
We may share your personal data with:
Service Providers:
- IT infrastructure and website hosting providers
- KYC/AML verification services
- Professional advisors (lawyers, auditors, consultants)
- Document management and secure file storage providers
Regulatory Authorities:
- Latvijas Banka (our regulator)
- Tax authorities
- Law enforcement (when legally required)
Third Parties:
- Our depository bank (for investor transactions)
- External auditors (for fund compliance)
We do not sell personal data to third parties. All service providers are bound by confidentiality agreements and process data only as instructed.
International Data Transfers
Your data is primarily stored and processed within the European Economic Area (EEA). If we transfer data outside the EEA, we ensure appropriate safeguards are in place, including:
- EU Standard Contractual Clauses
- Adequacy decisions by the European Commission
- Other legally approved transfer mechanisms
Data Retention
We retain personal data only as long as necessary for the purposes outlined in this policy:
- Prospective investors: 3 years from last contact (unless you request earlier deletion)
- Current investors: Duration of investment plus 10 years (regulatory requirement)
- Website visitors: Analytics data retained for 2 years
- Marketing contacts: Until you unsubscribe or request deletion
Legal and regulatory requirements may mandate longer retention periods in certain cases.
Your Rights
Under GDPR, you have the following rights:
- Right to access: Request a copy of your personal data
- Right to rectification: Correct inaccurate or incomplete data
- Right to erasure: Request deletion of your data (subject to legal obligations)
- Right to restriction: Limit how we process your data
- Right to data portability: Receive your data in a structured, machine-readable format
- Right to object: Opt out of certain processing activities, including marketing
- Right to withdraw consent: Where processing is based on consent
To exercise any of these rights, contact us at: info@vicmanscapital.com
We will respond within 30 days. If we cannot fulfill your request due to legal obligations, we will explain why.
Cookies and Tracking Technologies
Our website uses cookies to:
- Ensure basic website functionality
- Remember your preferences
- Analyze website traffic and usage patterns
- Improve user experience
You can manage cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.
For detailed information, see our Cookie Policy [link if separate policy exists].
Security Measures
We implement appropriate technical and organizational measures to protect your personal data, including:
- Encrypted data transmission (SSL/TLS)
- Secure password-protected systems
- Access controls and authentication
- Regular security assessments
- Employee confidentiality obligations
Despite our efforts, no data transmission over the internet is 100% secure. We cannot guarantee absolute security.
Children's Privacy
Our services are not directed at individuals under 18 years of age. We do not knowingly collect data from minors. If we become aware of such collection, we will delete the information promptly.
Changes to This Privacy Policy
We may update this Privacy Policy periodically. Material changes will be communicated via:
- Website notification
- Email to registered contacts
- Investor communications
The "Last Updated" date at the top indicates the most recent revision.
Contact Information
For privacy-related questions or to exercise your rights:
Vicman's Capital SIA Email: info@vicmanscapital.com Phone: +371 XXXX XXXX Address: Rīga, Ģertrūdes iela 133, LV-1009
Supervisory Authority: If you believe we have not addressed your privacy concerns adequately, you may lodge a complaint with:
Data State Inspectorate of Latvia Website: www.dvi.gov.lv Email: info@dvi.gov.lv
