Privacy Policy
Thank you for choosing to be part of our community at iAlta Private Markets d/b/a Helm Private Markets (“Helm Private Markets,” “Helm,” “Company,” “we,” “us,” or “our”). Helm is committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this Privacy Policy or our practices with regard to your personal information, please contact us at [[privacy@helmmarkets.com](mailto:privacy@helmmarkets.com)] or [[support@helmmarkets.com](mailto:support@helmmarkets.com)].
When you visit our website, [www.helmmarkets.com](http://www.helmmarkets.com), use our platform, or otherwise interact with our products, services, sales, marketing, events, or support channels, you may trust us with personal information. We take your privacy seriously. In this Privacy Policy, we explain what information we collect, how we use it, when we may share it, and what rights you may have in relation to it.
This Privacy Policy applies to all information collected, used, disclosed, transferred, stored, retained, or otherwise processed through our website, platform, products, services, sales, marketing, events, and related offerings, which we refer to collectively in this Privacy Policy as the “Services.” By continuing to interact with our Services, you consent to the practices described in this Privacy Policy. If you do not agree with any terms in this Privacy Policy, please discontinue use of our Services.
Please read this Privacy Policy carefully, as it will help you make informed decisions about sharing your personal information with us.
## 1. WHAT INFORMATION DO WE COLLECT?
### The personal information you disclose to us
**In Short:** We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register for the Services, request information about Helm or our Services, use our platform, participate in investor onboarding or transaction workflows, communicate with us, attend events, request support, submit forms, or otherwise contact us.
The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include, without limitation, the following:
**Contact and Business Information.** We may collect first name, last name, business email, personal email, phone number, business phone number, current address, business address, company name, job title, business entity information, corporate affiliations, business associates, and other similar information.
**Account and Platform Information.** We may collect usernames, passwords, account preferences, user roles, permissions, profile information, transaction activity, investor onboarding details, subscription documentation, reporting preferences, support requests, and other information you provide when using the Services.
**Financial and Transaction Information.** We may collect financial information such as bank account information, wire instructions, invoices, transaction details, payment amounts, billing information, capital call or distribution information, subscription information, investor commitment information, and other similar data necessary to provide the Services.
**Identity, Compliance, and Verification Information.** Depending on the Services you use, we may collect information necessary to support investor onboarding, KYC, AML, accreditation, suitability, sanctions screening, tax documentation, entity verification, beneficial ownership review, or other compliance-related workflows.
**Information You Voluntarily Provide.** We may collect other information that you voluntarily provide to us, including survey responses, event registration information, support communications, marketing preferences, feedback, and other content or materials you submit through the Services.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
### Information automatically collected
**In Short:** Some information, such as IP address, browser characteristics, device characteristics, and usage data, is collected automatically when you visit or use our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information may not reveal your specific identity, such as your name or contact information, but may include device and usage information, such as your IP address, browser type, device characteristics, operating system, language preferences, referring URLs, device name, country, general location information, information about how and when you use our Services, and other technical information.
This information is primarily needed to maintain the security and operation of our Services, provide functionality, improve user experience, and support internal analytics and reporting.
We may use Google Analytics and other similar services to collect information about your use of the Services. This may include data such as device type, operating system, browser type, IP address, pages visited, features used, and interactions with the Services.
We also use cookies and similar tracking technologies to collect and store certain information. These cookies may be set by us or our partners for purposes such as analytics, security, performance, personalization, and improving your experience.
## 2. HOW DO WE USE YOUR INFORMATION?
**In Short:** We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business purposes, including, but not limited to, the purposes described below. We process your personal information in reliance on our legitimate business interests, to enter into or perform a contract with you, with your consent, and/or to comply with legal obligations.
We use the information we collect or receive:
**To facilitate account creation and logon.** We may use your information to create, authenticate, maintain, and manage your account and access to the Services.
**To provide and deliver the Services.** We may use your information to provide platform functionality, support investor onboarding, manage investment-related workflows, process transaction information, facilitate document workflows, support payments and reconciliation, provide reporting, and deliver other requested Services.
**To send administrative information.** We may use your personal information to send you product, service, security, account, technical, and administrative information, including information about changes to our terms, conditions, policies, or Services.
**To fulfill and manage transactions.** We may use your information to fulfill and manage transactions, payments, subscriptions, commitments, capital calls, distributions, invoices, and related activities conducted through the Services.
**To support compliance and verification workflows.** We may use your information to support KYC, AML, identity verification, investor onboarding, sanctions screening, tax, accreditation, suitability, regulatory, and other compliance-related processes.
**To protect our Services.** We may use your information as part of our efforts to keep the Services safe and secure, including for fraud monitoring, fraud prevention, access control, security review, audit logging, and abuse prevention.
**To enable user communications and workflows.** We may use your information to enable communications and workflows between authorized users, administrators, investors, sponsors, issuers, advisors, service providers, or other participants, as applicable to the Services.
**To enforce our terms, conditions, and policies.** We may use your information to enforce our contractual rights, terms of service, policies, and other agreements.
**To respond to legal requests and prevent harm.** If we receive a subpoena, court order, government request, or other legal process, we may inspect and disclose data as necessary to determine how to lawfully respond.
**To manage user accounts.** We may use your information to manage user accounts, maintain account functionality, provide support, and keep the Services working as intended.
**To respond to inquiries and provide support.** We may use your information to respond to your inquiries, provide customer service, obtain feedback, and resolve issues related to the Services.
**For analytics and business purposes.** We may use your information for data analysis, identifying usage trends, measuring the effectiveness of marketing campaigns, improving the Services, developing new products and features, and enhancing your overall experience. We may use and store this information in aggregated or anonymized form so that it is not associated with individual end users and does not include personal information.
## 3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
**In Short:** We only share information with your consent, to comply with laws, to provide the Services, to protect rights, or to fulfill business obligations.
We may process or share your data with third parties based on one or more of the following legal bases:
**Consent.** We may process your data if you have given us specific consent to use your personal information for a specific purpose.
**Legitimate Interests.** We may process your data when it is reasonably necessary to achieve our legitimate business interests.
**Performance of a Contract.** Where we have entered into a contract with you or with an organization through which you access the Services, we may process your personal information to fulfill the terms of that contract.
**Legal Obligations.** We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, judicial proceedings, court orders, or legal process, including in response to public authorities to meet national security or law enforcement requirements.
**Vital Interests.** We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, potential threats to the safety of any person, illegal activities, or evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
**Vendors, Consultants, and Other Third-Party Service Providers.** We may share your data with third-party vendors, service providers, contractors, consultants, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples may include payment processing, identity verification, compliance screening, data analysis, hosting services, cloud infrastructure, email delivery, customer support, marketing, security services, analytics, and professional services.
Any payment transactions processed through a third party may be subject to that third party’s privacy policy, terms of use, and other applicable agreements. However, to the extent we are involved in processing payment transactions or processing information you provide through a payment transaction, such information is protected as described in this Privacy Policy.
We may allow selected third parties to use tracking technology on the Services, which may enable them to collect data about how you interact with the Services over time. This information may be used to analyze and track data, determine the popularity of certain content, understand online activity, and improve the Services. Unless otherwise described in this Privacy Policy, we do not share, sell, rent, or trade your personal information with third parties for their promotional purposes.
**Business Transfers.** We may share or transfer your information in connection with, or during negotiations of, any merger, financing, acquisition, reorganization, sale of company assets, or transfer of all or a portion of our business to another company.
**Affiliates.** We may share information with our affiliates, parent company, subsidiaries, or related entities where necessary to provide the Services, operate our business, support internal administration, or comply with applicable legal obligations.
**Third-Party Analytics.** We may use Google Analytics and other analytics providers to help us understand how users interact with the Services. These providers may use cookies and similar technologies to collect information about your use of the Services and provide analytics reporting.
**Your Choices.** You may be able to opt out of Google Analytics by using the Google Analytics Opt-Out Browser Add-on. Most web browsers also allow you to control cookies through their settings.
**Other Users and Authorized Participants.** When you share personal information or other content through the Services, that information may be visible to other authorized users or participants based on the applicable account, transaction, workflow, permission settings, or other functionality of the Services. You are responsible for ensuring that any information you submit through the Services is appropriate for the users or participants who may be able to access it.
## 4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
**In Short:** We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies, such as web beacons and pixels, to access or store information. These technologies may be used for authentication, security, performance, analytics, personalization, and marketing purposes. You may be able to control cookies through your browser settings or other available tools.
If we maintain a separate Cookie Policy, additional information about how we use such technologies and how you can refuse certain cookies will be set out in that Cookie Policy.
## 5. HOW LONG DO WE KEEP YOUR INFORMATION?
**In Short:** We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required or permitted by law.
We will keep your personal information only for as long as necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law, such as tax, accounting, regulatory, contractual, audit, or other legal requirements.
No purpose in this Privacy Policy will require us to keep your personal information for longer than necessary in relation to the Services, your account, applicable agreements, or our legal and business obligations.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible, such as because your personal information has been stored in backup archives, we will securely store your personal information.