Privacy Policy

Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Midgard, a Safanad Inc. brand (together with its affiliates, the “Company”, “us” or “we”), on behalf of Safanad Inc. and its affiliates, and sets forth the policies of the Company with respect to the collection, use, sharing and protection of the personal information of the Company’s prospective, current, and former clients collected through this website and in the course of our business. These policies apply to individuals only and may be changed at any time, provided a notice of such change is given to you. Please read this Privacy Notice carefully to understand what we do.

What personal information we collect, and how we do so

We collect personal information, such as your name, address, telephone number, and email address, for example, when you: (i) provide it to us in correspondence and conversations with the Company’s representatives; or (ii) submit an inquiry or request through this website. We also may collect your personal information from other sources, such as affiliates.

Why we process your personal information, and the applicable legal basis

We process the personal information that we collect for the following purposes:

For our everyday business purposes— such as to respond to your inquiries and provide our services. In these instances, we base our processing of personal information on our fulfilment of our contract with you (Article 6(1)(b) of the GDPR).

If you do not provide us with access to this information, we may be unable to offer you our services.

For other legitimate business purposes of us and our affiliates – to learn about your experience, and for other customer relations purposes which are based on your and our legitimate interests in monitoring and improving the services that we offer (Article 6(1)(f) of the GDPR).

For our individual or joint marketing purposes— to offer our products and services to you. In these cases, we will rely on your and our legitimate interests in offering and receiving our services (Article 13 of the e-Privacy Directive), or on consent (Article 6(1)(a) of the GDPR), in the event that you are not a current client or investor.

When our processing of personal information is based on your consent, you may withdraw your consent at any time, without affecting the lawfulness of the processing based on your consent before your withdrawal.

To respond to court orders and legal investigations – processing for these purposes may be based on the need to comply with legal obligations (when the obligation derives from EU law; Article 6(1)(c) of the GDPR) or on the legitimate interest of the Company to comply with foreign laws.

We may also process your personal information (e.g., IP addresses, device information, cookies) when you browse and navigate through our website, www.MidgardFinancial.com. We process this information in order to enable you to use our website, and to log visits and improve the site and the services offered through it (Article 6(1)(f) of the GDPR). You can learn more about how we process and use this information in our Cookies Policy.

How we protect and retain your personal information

To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings, among other technical and organizational measures.

In accordance with our document retention policy, your personal information will be stored for as long as our contractual relationship is ongoing, and for at least a sufficient number of years thereafter in order to ensure the Company’s compliance with legal obligations in each of the jurisdictions in which it is active.

How we may share your personal information

We may disclose your personal information to affiliates and to non-affiliated service providers that perform services on our behalf (such as IT, hosting, and professional advisers), and to respond to court orders and legal investigations. We will also release information about you if you direct us to do so. We do not share your information with non-affiliates for them to market to you.

We may also disclose information you provide to us to companies that perform marketing services on our behalf.

If such a disclosure is made, the Company will require such third parties to treat your private information with confidentiality. When personal information subject to the GDPR is processed and shared, the Company will rely on adequacy decisions, standard contractual clauses and/or other mechanisms to safeguard the personal information transferred.

We may also share information with our affiliates to market to you. You may prevent this type of sharing by emailing us at info@midgardfinancial.com.

If you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”), or if your personal information is processed by one of our affiliates in the EEA or the UK, you have the following rights regarding the Company’s processing of your personal information:

You have the right to request access to, rectification of, and erasure, of your personal information.

You have the right to object to or to request the restriction of our processing of your personal information.

You have the right to request the portability of your personal information.

You have rights with respect to automated decision making or profiling.

Any requests to exercise these rights may only be made effective insofar as the relevant personal information and the purposes of data processing are compatible with the exercise of such rights.

If you are dissatisfied with the manner in which we have processed your personal information and wish to lodge a complaint, you may contact us, and you also may make a complaint to the supervisory authority of the country where our affiliate has provided you with services or where you reside.

Contact us

If you have any questions about this Privacy Notice, or wish to exercise any of the above rights, email info@midgardfinancial.com or contact us:

Safanad Inc. 505 Fifth Ave, 15th Floor New York, NY 10017 +1 212 468 5600

Cookie policy

All cookies used by and on Midgard’s site are used in accordance with current cookie law.

Before cookies are placed on your computer or device, you will be shown a cookie notice requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling Midgard to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however, certain features of the site may not function fully or as intended.

Certain features depend on cookies to function. Cookie law deems these cookies to be “strictly necessary.” Midgard has taken great care to ensure that your privacy is not at risk by allowing them.

Midgard’s site may place and access certain first party cookies on your computer or device. First party cookies are those placed directly by Midgard and are used only by Midgard. It uses cookies to facilitate and improve your experience of the site and to provide and improve its services. Midgard has carefully chosen these cookies and has taken steps to ensure that your privacy and personal data is protected and respected at all times.

This site also uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyze anonymous usage information, enabling Midgard to better understand how the site is used. This, in turn, enables Midgard to improve the site and the services offered through it. You do not have to allow Midgard to use these cookies, however its use of them does enable Midgard to continually improve the site, making it a better and more useful experience for you.

With respect to the Google Analytics cookies, please note that Midgard has entered into a data processing agreement with Google that provides that the last octet of your IP address is masked when Midgard provides information to Google, that it does not use any other Google services in combination with Google Analytics cookies and that it does not share any data with Google for advertisement purposes. To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit https://www.allaboutcookies.org/.