Privacy Policy

1. Introduction

Welcome to Reform Capital ("we," "us," or "our"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard information obtained from users of our agricultural investment platform at reformcapital.ltd and related services (collectively, the "Services").

By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with our practices, please do not use our Services.

2. Information We Collect

2.1 Personal Information

When you register for an account or use our investment services, we collect the following personal information:

2.2 Investment Data

We collect information related to your investment activities, including transaction history, portfolio performance, investment preferences, and communication records regarding your agricultural investment projects.

2.3 Automatically Collected Information

Our platform automatically collects certain technical information when you visit our website, including cookies, log files, and usage data to improve your experience and ensure platform security.

3. How We Use Your Information

Reform Capital uses your personal information for the following purposes:

• Account Management: Creating and maintaining your investor account
• Investment Services: Processing investments, managing portfolios, and providing agricultural investment opportunities
• Compliance: Meeting KYC/AML requirements and regulatory obligations
• Communication: Sending investment updates, market insights, and account notifications
• Customer Support: Responding to inquiries and providing technical assistance
• Risk Management: Assessing investment suitability and preventing fraud
• Platform Improvement: Enhancing our services based on user feedback and analytics

4. Information Sharing and Disclosure

Reform Capital maintains strict confidentiality of your personal information. We do not sell, rent, or trade your personal data to third parties. We may share your information only in the following limited circumstances:

• Regulatory Compliance: When required by financial regulators or legal authorities
• Service Providers: With trusted partners who assist in delivering our services (under strict confidentiality agreements)
• Business Transfers: In the event of a merger, acquisition, or sale of assets
• Legal Requirements: To comply with court orders, subpoenas, or legal processes
• Safety and Security: To protect the rights, property, or safety of our users and platform

5. Data Security

We implement comprehensive security measures to protect your personal information:

• Encryption: All sensitive data is encrypted both in transit and at rest using industry-standard protocols
• Access Controls: Strict authentication and authorization procedures limit access to authorized personnel only
• Regular Audits: Periodic security assessments and penetration testing
• Infrastructure Security: Secure hosting environments with 24/7 monitoring
• Staff Training: Regular training on data protection and security best practices
• Incident Response: Established procedures for handling potential security breaches

While we employ robust security measures, no system is completely secure. We continuously monitor and update our security practices to maintain the highest level of protection.

6. Your Rights and Choices

As a Reform Capital user, you have the following rights regarding your personal information:

Access and Portability

You can request a copy of the personal information we hold about you and receive it in a structured, machine-readable format.

Correction and Updates

You can update your personal information through your account dashboard or by contacting our support team.

Data Deletion

You can request deletion of your account and associated personal data, subject to regulatory requirements that may mandate data retention.

Communication Preferences

You can manage your communication preferences and opt-out of non-essential marketing communications at any time.

7. Account Deletion

To request account deletion, please contact our support team. Upon verification of your identity, we will:

• Process the deletion within 30 business days
• Permanently remove your personal information from our active systems
• Retain only the minimum data required for regulatory compliance
• Provide confirmation of successful deletion

Please note: Account deletion will result in the permanent loss of access to your investment portfolio and historical data.

8. International Data Transfers

Reform Capital may transfer your personal information to countries outside your jurisdiction for processing and storage. When we do so, we ensure appropriate safeguards are in place through:

• Standard contractual clauses approved by data protection authorities
• Adequacy decisions recognizing equivalent protection levels
• Certification schemes and codes of conduct

9. Children's Privacy

Reform Capital's services are designed for adults aged 18 and above. We do not knowingly collect personal information from individuals under 18 years of age. If we become aware that we have collected information from a minor, we will take immediate steps to delete such information.

10. Fraud Prevention, Security Monitoring & Prohibited Automated Activity

To protect the integrity, security, and proper functioning of our platform, Reform Capital actively monitors account activity for suspicious, abusive, fraudulent, or unauthorized behavior. This monitoring is necessary to safeguard our infrastructure, investors, and overall platform stability.

Prohibited activities include, but are not limited to:

• Use of bots, automated scripts, crawlers, or artificial transaction systems
• Generation of excessive, repetitive, or non-genuine transactions
• Attempts to manipulate investment records, returns, or platform metrics
• Unauthorized access attempts or circumvention of security controls
• Any activity designed to overload, disrupt, or degrade platform performance