Privacy Policy

1. Scope of This Privacy Policy

This Privacy Policy applies to the website located at ttfkinvest.hair and to every service delivered by TCLAWX LLC from its office at 20400 Saratoga Los Gatos Rd, Saratoga - 95070-5927, United States (US). It covers information collected through this website, through email and telephone contact, through the written inquiry form, and through the ordinary conduct of an engagement.

The policy does not apply to information that a client stores in systems we do not control, nor to the independent practices of counterparties, advisers or regulators. Where we act as a processor for a client who is itself a controller, the terms of the engagement letter control the processing relationship and this policy supplements rather than replaces those terms.

By using this website or instructing TCLAWX LLC, you confirm that you have read this policy. If you do not accept the practices described here, please do not submit information to the bench and contact us so that an alternative arrangement can be discussed.

2. Who We Are and How to Reach Us

The responsible entity for the information described in this policy is TCLAWX LLC, a professional services practice operating in the computer systems design and related services sector with an emphasis on transaction counsel and investment compliance advisory work. Our registered address is 20400 Saratoga Los Gatos Rd, Saratoga - 95070-5927, United States (US).

Questions about this policy, requests to exercise a privacy right, or concerns about how information has been handled may be sent to invest@ttfkinvest.hair or raised by telephone at +12248026551. Written inquiries are preferred because they preserve a complete record of the request and the response. We answer privacy correspondence in the order received and normally within a small number of business days.

Where this policy refers to the bench, the house or the practice, it refers to TCLAWX LLC and to the personnel who carry out engagements under its direction. Where it refers to the register, it refers to the controlled set of engagement files, correspondence logs and delivery records that we maintain to keep our work traceable.

3. Information We Collect

We collect information in three broad ways. First, information that clients, prospective clients and counterparties provide directly. Second, limited technical information generated automatically when this website is visited. Third, information lawfully obtained from public registries, counterparties and professional advisers in the course of an engagement.

The categories we may hold include identity and contact details, corporate and beneficial ownership information, financial and transactional particulars, correspondence, authority documents, due diligence materials, compliance records and filing confirmations. The precise scope depends on the matter. A short consultation generates very little information, while an integrated transaction mandate generates a substantial file.

We do not seek information that is unnecessary for the stated purpose. Where an item is optional, we indicate that it is optional and explain the consequence of not providing it. Where an item is required by law, we explain the requirement so that the client can supply the item knowingly.

4. Information Provided Directly by Clients

Most of the information we hold arrives because a client, a prospective client or a counterparty chooses to send it. The written inquiry form on the contact page collects a name, an email address, an optional subject line and a message. That information is used to understand the instruction and to reply to it.

During an engagement, we receive documents and data that are necessary to prepare or review an instrument. These typically include constitutional documents, cap tables, board minutes, financing agreements, subscription documents, investor registers, compliance policies, valuation records and correspondence with authorities.

We may also receive special category or sensitive information where a matter requires it, for example where beneficial ownership disclosure engages personal data or where a regulatory filing requires identifying particulars. Where sensitive information is supplied, we restrict access to the personnel who must see it, we keep it in the controlled register and we retain it only as long as the engagement and the professional record require.

Please send only what the bench asks for. If you are unsure whether a document is needed, describe it first and we will confirm whether it should be transmitted.

5. Information Collected Automatically

When you visit this website, the hosting infrastructure may record technical information such as the internet protocol address, the browser type, the operating system, the referring page, the pages requested and the time of the request. This information supports the operation, security and reliability of the site.

We use this technical information in aggregate to understand which pages are useful, to detect abusive traffic and to diagnose faults. We do not use it to build advertising profiles, and we do not sell it. Where the hosting provider keeps server logs for security purposes, those logs are subject to the provider commitments described in the processor section of this policy.

You can reduce the technical information available to any website by using browser privacy controls, disabling scripting, or connecting through a network that conceals the originating address. Some of those measures may affect how the site renders, but the substantive content remains available without JavaScript.

6. Information from Third Parties

An engagement often requires us to verify facts. We may therefore obtain information from corporate registries, land and security registries, regulators, counterparties, banks, auditors, accountants, other counsel and publicly available databases. We use this information to confirm authority, ownership, standing and compliance posture.

Where we receive information from a counterparty in a negotiation, we treat it as confidential to the extent the counterparty requests and the engagement permits. Where we receive information from a public registry, we record the source and the date of retrieval so that the file shows when the position was verified.

We do not purchase marketing lists and we do not acquire personal data brokers. Information from third parties is obtained for a defined engagement purpose and is handled under the same protections described in this policy.

7. Why We Process Information

We process information to answer inquiries, scope engagements, prepare and review documents, conduct due diligence, maintain governance records, perform compliance reviews, prepare and submit filings, manage the register and communicate with clients and counterparties.

We also process information to keep our own practice sound: to record advice given, to manage conflicts, to maintain professional records, to pursue or defend legal claims, to meet insurance and audit requirements and to comply with the professional and regulatory rules that apply to a transaction counsel practice.

Where we process information for a purpose that is new and unrelated to the original purpose, we will explain the new purpose and, where the law requires it, seek consent before proceeding.

8. Legal Bases for Processing

Where a legal framework requires a stated basis for processing, we rely on one or more of the following. Performance of a contract, where processing is necessary to deliver an engagement that has been instructed. Legitimate interests, where processing supports the operation of the practice in a way that does not override the rights of the individual. Legal obligation, where a rule requires us to collect, retain or disclose information. Consent, where the individual has given clear permission and no other basis applies.

Where we rely on consent, the consent may be withdrawn at any time by writing to invest@ttfkinvest.hair. Withdrawal does not affect processing carried out before the withdrawal, and it does not affect processing that rests on another lawful basis, such as a legal obligation to retain a professional record.

Where we rely on legitimate interests, we balance the interest against the reasonable expectations and rights of the individual. The register records the balancing assessment so that the reasoning can be reviewed later.

9. How We Use Engagement Records

A transaction counsel practice lives on its records. We maintain an engagement register that holds drafts, comments, correspondence, authority evidence, filing confirmations and closing documents. The register is controlled, indexed and searchable so that any material question about a matter can be answered from the file.

We use the register to deliver the engagement, to support later advice to the same client, to satisfy professional record keeping duties and to reconstruct the history of a negotiation if a dispute arises. Access is limited to the personnel who need it for the matter at hand.

We may also use de identified and aggregated information drawn from engagements to improve our own templates, checklists and training materials. Aggregated material does not identify any client, counterparty or individual, and it is not used to market to anyone.

10. Cookies and Similar Technologies

This website is deliberately light. It does not operate an advertising network, it does not embed third party analytics that track individuals across sites, and it does not set cookies for profiling. Any cookies that are present are limited to those strictly necessary for the hosting layer to serve pages securely.

If the site is later extended to include optional analytics, this policy will be updated before the change takes effect and the change will be described in the section on updates. Any optional technology will be presented in a way that permits a clear choice, and the site will continue to function if the optional technology is declined.

You can block or delete cookies through your browser settings. Blocking strictly necessary cookies may affect the ability of the hosting layer to serve the site correctly, but it will not prevent you from reading the substantive content or from contacting the bench by email or telephone.

11. How We Share Information

We do not sell information. We do not rent information. We do not trade information for marketing purposes. We share information only in the limited circumstances described in this section.

We share information with the client whose matter is being handled, with counterparties and their advisers where the engagement and the client require it, with courts, registries and regulators where a filing or an order requires it, and with professional advisers such as auditors and insurers where the practice must account for its work.

We may also share information where disclosure is necessary to establish, exercise or defend a legal claim, to protect the rights or safety of a person, or to comply with a lawful request from a body with competent authority. Where a request is broad or unclear, we seek clarification and, where possible, notify the client so that an objection can be considered.

Where information is shared under professional confidentiality, the recipient is bound by an equivalent duty and the disclosure is recorded in the register.

12. Service Providers and Processors

We rely on a small number of service providers to operate the practice. These include the website hosting provider, the email provider, document storage and backup services, and communications services. Each provider processes information only on our documented instructions and only for the purposes we specify.

Before a provider is engaged, we review its security posture, its confidentiality commitments and its handling of subprocessors. Where a provider is itself a regulated professional service, we confirm the applicable duty of confidence. Providers that cannot meet our standard are not engaged.

If a provider is replaced, the outgoing provider is required to return or securely delete the information it holds, and the incoming provider must satisfy the same review before any transfer takes place. The register records the change so that the custody history of a file remains complete.

13. International Transfers

TCLAWX LLC is based in the United States, and the register is maintained in the United States. Where an engagement involves a client, counterparty or adviser outside the United States, information may be transferred across borders so that the matter can be conducted.

Where a transfer is subject to a legal framework that requires safeguards, we put appropriate measures in place. These may include contractual commitments, a documented assessment of the destination framework and, where the law permits, the explicit direction of the client.

We keep the transfer assessment in the register. If you would like to know which safeguard applies to a particular matter, write to invest@ttfkinvest.hair and we will explain it in plain language.

14. How Long We Keep Information

We keep engagement records for as long as the professional relationship and the applicable record keeping rules require. Transaction and compliance files are typically retained for a substantial period because a transaction can be examined, financed or disputed years after closing.

Inquiry correspondence that does not become an engagement is kept for a shorter period, after which it is securely deleted unless the sender asks that it be retained. Website technical logs are kept only as long as the hosting provider needs them for security and reliability.

When a retention period ends, information is deleted or irreversibly anonymised. Where deletion is not immediately possible because information sits in a secure backup, the backup is isolated and the information is deleted when the backup cycle next completes.

15. How We Protect Information

We apply administrative, technical and physical safeguards to information. These include role based access control, encrypted transmission, protected storage, second reader review of significant documents, access logging and periodic review of who holds access to the register.

Personnel are bound by confidentiality undertakings and receive training on handling sensitive material, recognising intrusion attempts and responding to incidents. Access is granted for a matter and withdrawn when the matter closes or when a person leaves the practice.

No safeguard is absolute. We therefore design the register so that the effect of any single failure is contained, we keep backups that can restore a file, and we rehearse the response process so that a real incident is handled with a plan rather than improvised.

16. Your Privacy Rights

Depending on where you live, you may have the right to know whether we hold information about you, to request a copy, to request correction of inaccurate information, to request deletion where no overriding obligation requires retention, to request restriction of certain processing, to object to processing based on legitimate interests and to request portability of information you provided.

You may also have the right not to be subject to a decision based solely on automated processing that produces a legal or similarly significant effect. We do not currently make such decisions, and the section on automated decision making explains the position in full.

To exercise a right, write to invest@ttfkinvest.hair with enough detail for us to understand the request and to verify your identity. We will confirm receipt, explain what we can do and complete the request within the period the applicable law allows. Where a request concerns information held for a client engagement, we may need to refer the request to the client before responding.

We do not charge a fee for a reasonable request. Where a request is manifestly unfounded or excessive, we may decline it or charge a proportionate fee, and we will explain the reason in writing.

17. Privacy for Children

The services of TCLAWX LLC are intended for businesses, institutions and adult professionals. This website is not directed to children, and we do not knowingly collect information from a child through the site.

If you believe that a child has sent information to the bench, write to invest@ttfkinvest.hair and we will locate the material, delete it where no legal obligation requires retention, and confirm the action taken.

Where a corporate engagement incidentally involves information about a minor, for example in a succession or ownership matter, that information is handled under the same confidentiality and access controls as any other sensitive material, and it is retained only as long as the matter requires.

18. Marketing Communications

We send substantive communications about matters and engagements as part of the service. We send general updates about the practice only where a recipient has asked to receive them or where the recipient is an existing client and the update is closely related to work already performed.

Every general update includes a simple way to stop receiving further updates, and a request to stop is honoured promptly. A request to stop general updates does not prevent us from sending communications that are necessary to deliver an active engagement or to meet a legal obligation.

We do not share contact details with third parties for their own marketing, and we do not add an inquiry contact to a general update list without a clear request to do so.

19. Professional Confidentiality

Confidentiality is not merely a privacy preference at this practice; it is a professional obligation. Information received in the course of an engagement is treated as confidential, and it is disclosed only where the client directs, where the engagement requires or where the law compels.

Where we act for more than one party, the engagement letter states how confidential information is shared and how conflicts are managed. Where a matter becomes contentious, we follow the applicable professional rules on privilege and on the treatment of material prepared in anticipation of dispute.

The confidentiality obligation continues after an engagement ends. It is not limited by the deletion of a file, and it applies to every member of the bench who had access to the matter.

20. Automated Decision Making

We do not use automated processing to make decisions that produce a legal or similarly significant effect on an individual. Engagement decisions are made by people, and they are recorded with the reasoning that supported them.

We may use software to organise documents, to search the register, to check a filing calendar or to detect unusual access patterns. These tools support human judgement; they do not replace it, and they do not decide whether an engagement is accepted, how a matter is advised or what a client is charged.

If a future tool were to change that position, this policy would be updated before the tool took effect, and an explanation of the logic and the available safeguards would be provided.

21. Data Breach Response

We maintain a response process for incidents that affect the confidentiality, integrity or availability of information. The process covers containment, assessment, notification and remediation, and it names the people responsible for each step.

Where an incident creates a risk to individuals, we notify affected parties and the competent authority within the period the applicable law requires, describing what happened, what information was involved and what steps are being taken. Where the risk is low, we still record the incident and the assessment so that the reasoning is documented.

After an incident we review the cause and adjust the controls that failed. The review is recorded in the register, and the changes are tested rather than assumed.

22. Third Party Links

This website may link to external resources such as registries, regulators or professional bodies. Those resources are operated by others and are governed by their own privacy notices.

We choose links with care and link only to resources that appear relevant to the practice. We do not control the content, the security or the privacy practices of an external site, and a link does not imply that we endorse every practice of the operator.

If you follow an external link, read the privacy notice of that site before providing information. If a link on this site appears to point somewhere unexpected, write to invest@ttfkinvest.hair so that it can be checked and corrected.

23. Changes to This Privacy Policy

We review this policy when the practice changes, when the law changes or when a control changes in a way that affects how information is handled. When a change is material, we update the policy and describe the change in plain language.

The current version of this policy is the one published on this page. Where a change affects an active engagement in a way that requires a decision, we contact the client directly rather than relying on the published page alone.

Continued use of this website after a change takes effect indicates acceptance of the updated policy. If you do not accept an update, stop using the site and contact the bench so that the effect on any active matter can be discussed.

24. How to Raise a Concern

If you believe that information has been handled inconsistently with this policy, write to invest@ttfkinvest.hair with a description of the concern and any supporting detail. We acknowledge the concern, investigate it, and reply with the outcome and the action taken.

If you are not satisfied with the response, you may raise the matter with the competent supervisory authority in your jurisdiction. We will cooperate with a supervisory inquiry and provide the information that the authority requests.

This policy is maintained by TCLAWX LLC at 20400 Saratoga Los Gatos Rd, Saratoga - 95070-5927, United States (US). Telephone contact is available at +12248026551 during bench hours, and written contact is available at any time at invest@ttfkinvest.hair.