Last Updated: March 30, 2026
CapX100 ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.
Data Controller: Abshir Sharif
Company: CapX100
Location: Amsterdam, Netherlands
Email: [email protected]
We collect the following categories of personal data from clients:
Portfolio Data: Holdings, securities identifiers, quantities, prices, and performance metrics.
Fund Information: Fund name, strategy, inception date, AUM, and benchmark details.
Contact Information: Name, email, phone, organization, and job title.
Custodian Files: Raw data exports from custodians (Schwab, Fidelity, IBKR, etc.).
We process your data based on the following legal grounds under GDPR:
Contract Performance (Article 6(1)(b)): Processing is necessary to provide analytics services under our service agreement.
Legal Obligation (Article 6(1)(c)): Processing is required to comply with regulatory requirements (AIFMD, GIPS, MiFID III).
Legitimate Interest (Article 6(1)(f)): Processing is necessary for business operations, security, and fraud prevention.
We use collected data for the following purposes:
Generating risk, performance, and compliance analytics reports
Providing regulatory evidence and audit-trail documentation
Delivering client-ready PDF packets and Excel workbooks
Ensuring data security and detecting unauthorized access
Complying with legal and regulatory obligations
We implement industry-standard security measures to protect your data:
Secure Transfer: Data is transferred via ShareFile (Progress Software), SOC 2 Type II and ISO 27001 certified.
Encryption in Transit: All data transfers use TLS 1.3 encryption.
Encryption at Rest: Data is encrypted using AES-256 encryption.
Infrastructure: EU-hosted infrastructure, fully GDPR compliant.
Access Control: Data access is restricted to authorized personnel only.
Portfolio and performance data is retained only during the active engagement period. Upon termination of services, all client data is securely deleted within thirty (30) calendar days. Written confirmation of deletion is available upon request.
We do not share your data with third parties except as follows:
ShareFile (Progress Software): Data processor for secure file transfer and storage.
Legal Requirements: Disclosure may occur if required by law, regulation, or court order.
No Marketing: We do not sell or share your data for marketing purposes.
If data is transferred outside the EU/EEA, we ensure appropriate safeguards through Standard Contractual Clauses (SCCs) or adequacy decisions as required by GDPR Article 46.
Under GDPR, you have the following rights:
Right of Access: You may request a copy of your personal data.
Right to Rectification: You may request correction of inaccurate data.
Right to Erasure: You may request deletion of your data ("right to be forgotten").
Right to Restrict Processing: You may request limitation of how we use your data.
Right to Data Portability: You may request your data in a portable format.
Right to Object: You may object to certain types of processing.
To exercise these rights, contact us at [email protected].
For clients in the EU or handling EU personal data, a separate Data Processing Agreement (DPA) must be executed before any data transfer. This DPA complies with GDPR requirements and outlines our obligations as a data processor.
If you have questions about this Privacy Policy or wish to exercise your rights:
Email: [email protected]
You also have the right to lodge a complaint with your local data protection authority (e.g., the Dutch Data Protection Authority - Autoriteit Persoonsgegevens).
We may update this Privacy Policy at any time. Material changes will be communicated via email or posted on our website with an updated effective date.
This Privacy Policy is governed by the laws of the Netherlands and the GDPR.
Data Controller: Abshir Sharif, CapX100, Amsterdam, Netherlands | Email: [email protected]