Privacy Policy

1. Scope and Definitions
This Privacy Policy explains how Passage Capital collects, uses, stores, and protects personal data obtained through the site. The term "personal data" refers to information that can be linked to specific individuals directly or indirectly, such as name and email address. This policy applies to all site visitors who access content or use contact forms. Explanations in this document are organized neutrally and informatively so visitors understand data management processes. This site does not provide financial transaction services and does not request sensitive financial data.

2. Categories and Sources of Personal Data
Passage Capital may collect personal data provided directly by visitors, such as full name, email address, subject, and message content sent through contact forms. In addition, certain technical data such as IP addresses, device types, and site usage information may be obtained through standard technologies, such as server logs or cookies. Such data is used for technical monitoring and general site management. Passage Capital does not collect financial data such as account numbers or payment cards, and does not request official identity information beyond basic communication needs.

3. Purposes and Basis for Processing Personal Data
Personal data is used for purposes of answering questions, managing communication, and maintaining internal records related to correspondence. Data use is based on consent given by visitors when submitting forms and checking consent boxes, as well as reasonable electronic system management needs. Data may also be used for general analysis of site usage in ways that do not directly identify individuals. Passage Capital does not use personal data for profile creation, product offers, or direct marketing activities.

4. Data Storage and Retention
Personal data is stored for as long as necessary to fulfill purposes explained in this Privacy Policy, including correspondence management and internal record maintenance. After such purposes are fulfilled or when data is no longer relevant, data may be deleted or anonymized according to applicable internal procedures. Retention periods may vary depending on communication context and documentation needs. Passage Capital strives to ensure that stored data remains accurate and updated according to information provided by visitors.

5. Data Subject Rights
Visitors as data subjects have the right to request explanations about personal data managed, including confirmation of data existence and summaries of related information. Visitors may also submit correction requests if stored data is inaccurate or no longer relevant. In addition, visitors may request deletion of certain data as long as it does not conflict with reasonable data retention obligations, and may withdraw previously given consent for data processing. Requests related to these rights may be submitted through contact information listed above.

6. Data Controller, Data Processor, and Disclosure to Third Parties
Passage Capital acts as data controller for personal data collected through this site. In performing technical functions, Passage Capital may cooperate with certain service providers as data processors that assist in operating technology infrastructure, such as hosting or storage services. Any cooperation with third parties is done with arrangements intended to maintain data confidentiality and security. Personal data is not sold or transferred for third-party marketing purposes, and disclosure is only done to the extent necessary to operate site functions or fulfill relevant legal obligations.

7. Data Security and Cross-Border Transmission
Passage Capital implements reasonable measures to maintain personal data security, including technical and administrative safeguards according to characteristics of services provided. Under certain conditions, data may be processed or stored outside the United States through technology service providers. In such cross-border transmission, Passage Capital strives to ensure that data management remains consistent with applicable regulations and based on adequate impact assessments. Visitors can still exercise rights related to personal data as explained in this Privacy Policy.

8. Users Under Certain Age and Policy Changes
This site is not specifically intended for children under 17 years of age, and collection of personal data from individuals in that age group requires consent from parents or legal guardians. If it is known that data from children under 17 years of age is collected without such consent, Passage Capital may conduct reviews and reasonable deletion steps. This Privacy Policy may be updated from time to time to adjust to system management developments and relevant legal provisions. Any changes will be marked through date updates in the "Last Updated" section.

For more information, please use the contact information above.