Introduction
Higher Ground International LLC (Higher Ground, we, our) is committed to handling personal information responsibly.
This privacy policy explains how and why we collect, use, disclose and protect personal information, and the rights individuals may have in relation to that information.
It applies to personal information we receive directly from you or obtain from other sources in connection with our website, assessment process, client engagements and other business activities. This includes information about people who submit assessments or become clients, as well as counterparties, founders, project personnel, advisers and others who may be relevant to our work.
We may provide additional privacy information when we collect personal information from you. Any additional notice should be read together with this privacy policy.
Personal information or personal data means information relating to an identified or identifiable individual.
If you have any questions about this privacy policy or how we handle personal information, please contact us at contact@higherground.io.
1. Personal information we collect and how we collect it
The personal information we collect depends on how you interact with us and the nature of the relevant assessment or recovery matter.
It may include:
- your name, email address, telephone number, country, Telegram username, organisation, role and other contact or identity information;
- information submitted through our assessment process, including details of an investment, transaction, project or other arrangement, the amount or value involved, relevant dates, the parties involved, what happened and any steps already taken;
- contracts, SAFTs, token warrants, correspondence, transaction records, screenshots, statements, reports and other information or evidence relevant to a recovery matter;
- wallet addresses, blockchain transactions, payment information, settlement arrangements and other financial or digital asset information;
- information used to verify identity, authority, ownership or entitlement, or for legal, regulatory, sanctions, fraud prevention or other compliance purposes;
- information about counterparties, founders, project personnel, advisers, representatives, witnesses and other people relevant to an assessment or recovery matter;
- communications with us, including emails, Telegram messages, enquiries and instructions; and
- technical information generated when you use our website, such as IP address, device and browser information, log data and information collected through cookies or similar technologies.
We collect most personal information directly from you when you submit an assessment, communicate with us or become a client.
We may also obtain information from clients and other people, contracts and correspondence, counterparties, public blockchain networks, blockchain analytics, corporate and regulatory registers, court records, websites, social media, news sources, professional advisers, regulators, enforcement authorities and other lawful sources.
Some personal information may receive additional protection under applicable privacy laws. Where this applies, we will handle it in accordance with those requirements.
You may browse public parts of our website without identifying yourself. However, we require certain information about you and the relevant investment or arrangement in order to assess a proposed matter or provide our services.
Our services are intended for adults and are not directed at children.
2. Why we use personal information
We may use personal information to:
- receive and assess proposed recovery matters;
- determine whether we would like to take a matter forward;
- communicate with you and request supporting information or documents;
- verify identity, authority, ownership and entitlement;
- onboard clients and administer our engagements;
- investigate recovery matters and develop the available evidence;
- prepare evidential records, analyses and chronologies;
- identify and communicate with counterparties and other relevant people;
- seek and negotiate commercial resolutions;
- coordinate settlements and the receipt and distribution of recoveries;
- prepare and, where authorised, make submissions to regulatory or enforcement authorities;
- administer fees, payments and other aspects of our engagements;
- comply with legal, regulatory and compliance requirements;
- detect and prevent fraud, misuse, security incidents and unlawful activity;
- establish, exercise or defend legal rights and resolve disputes;
- operate, secure and improve our website, systems and services;
- maintain appropriate business and operational records; and
- use anonymised or de-identified information for internal analysis and to describe our experience and outcomes without identifying the relevant client or matter.
Where applicable privacy law requires a legal basis for processing, we may rely on taking steps at your request before entering into a contract, performing our contract with you, complying with legal obligations, our legitimate interests in operating our business and pursuing commercial recovery, your consent where required, or another basis permitted by applicable law.
We will not use personal information for a purpose that is materially incompatible with the purpose for which it was collected unless permitted by law.
If you do not provide information that we reasonably require, we may be unable to complete an assessment, accept a matter, provide our services or process a recovery.
3. Assessments and recovery matters
You may provide personal information to us when submitting a matter for assessment through our website, Telegram or another channel.
We use that information to assess the proposed matter against our acceptance criteria, determine whether we would like to take it forward and communicate with you about the assessment. We may also request further information or supporting documents before making a decision.
Submitting an assessment does not create an engagement with Higher Ground or require us to accept or act on the matter. Any assessment reference provided to you is for tracking and administration purposes only.
If we subsequently accept the matter and the applicable engagement arrangements are in place, information collected during the assessment may be used in connection with the relevant recovery matter.
If we do not take a proposed matter forward, we may retain an appropriate record where reasonably necessary for record keeping, fraud prevention, identifying related or duplicate submissions, responding to future enquiries or establishing or defending legal rights.
Please do not provide identity documents, supporting evidence or other sensitive documents through our initial assessment process unless we ask you to do so.
Our work may also involve personal information about people who have not provided that information directly to Higher Ground, including counterparties, founders, project personnel, advisers and other individuals relevant to an assessment or recovery matter.
We use that information where reasonably necessary to assess or investigate a matter, pursue commercial recovery, undertake authorised regulatory or enforcement activity, meet compliance requirements or establish, exercise or defend legal rights, and as otherwise permitted by law.
4. How we share personal information
We may disclose personal information where reasonably necessary for the purposes described in this privacy policy.
Depending on the circumstances, we may share information with:
- our personnel, contractors and service providers;
- website hosting, cloud storage, communications, case management and technology providers;
- identity verification, compliance, cybersecurity, blockchain analytics and fraud prevention providers;
- counterparties and other people relevant to a recovery matter;
- banks, wallet providers and other payment or settlement service providers;
- external legal counsel and other professional advisers;
- regulatory, enforcement, governmental and judicial authorities;
- our professional advisers;
- a purchaser or successor in connection with a proposed or completed sale, merger, restructuring or transfer of our business; and
- any other person where you authorise or direct us to disclose the information.
We may also disclose personal information where required or permitted by law or where reasonably necessary to protect our rights, systems, clients or other people.
Where a service provider processes personal information on our behalf, we require appropriate confidentiality and security safeguards and require the information to be processed only for authorised purposes. Where appropriate, we also require equivalent protections to apply to subprocessors.
We may use or disclose anonymised, aggregated or de-identified information where it does not identify an individual.
5. Technology and third-party platforms
Our website may use cookies and similar technologies to operate and secure the website, remember preferences and understand how it is used.
Where required by applicable law, we will obtain consent before using non-essential cookies or similar technologies and provide a way for you to manage your preferences.
You may choose to interact with Higher Ground through Telegram or another third-party platform. Information you provide through those services will also be processed by the relevant platform in accordance with its own terms and privacy practices.
If you use the Higher Ground Telegram bot, information you send to the bot is transmitted through Telegram and made available to Higher Ground and any service provider operating the bot on our behalf.
We do not use Telegram to collect supporting documents as part of the initial assessment process. If we need documents or particularly sensitive information, we may ask you to provide them through another channel.
Use of Telegram is optional.
We may use artificial intelligence and other automated tools to assist us in collecting, organising, searching, summarising or analysing information. Higher Ground remains responsible for how those tools are used and does not rely solely on automated decision-making to determine whether to accept a proposed matter.
Our website and communications may also contain links to websites or services operated by third parties. Those third parties have their own privacy practices, and this privacy policy does not apply to information they collect independently from us.
6. International transfers
Higher Ground operates internationally. Our clients, applicants, counterparties and service providers may be located in different countries.
Personal information may therefore be accessed from, transferred to or stored in a country other than the country in which it was originally collected, including the United States.
Privacy and data protection laws may differ between countries.
Where applicable law requires safeguards for an international transfer of personal information, we will use an appropriate lawful transfer mechanism or other permitted basis.
You may contact us at privacy@higherground.io if you would like further information about how we protect personal information transferred internationally.
7. Retention and security
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected or subsequently lawfully used.
The appropriate period will depend on factors such as whether the information relates to an assessment or accepted matter, whether an engagement or recovery process remains active, legal or compliance requirements, the nature of the information, the need to prevent fraud or duplicate submissions, and the period during which a claim or dispute may arise.
When personal information is no longer reasonably required, we will delete, anonymise or securely dispose of it, subject to any legal requirement or legitimate need to retain it.
We use administrative, technical and organisational safeguards designed to protect personal information against unauthorised access, disclosure, alteration, loss, misuse or destruction.
These measures may include access controls, authentication measures, security monitoring and restrictions on access to information according to business need.
No system or method of transmitting or storing information can be guaranteed to be completely secure.
8. Your privacy rights
Your privacy rights depend on where you live and the laws that apply to you.
Depending on your circumstances, you may have rights to:
- access personal information we hold about you;
- ask us to correct inaccurate or incomplete information;
- request deletion of certain information;
- restrict or object to certain processing;
- obtain certain information in a portable format;
- withdraw consent where our processing is based on consent;
- exercise applicable rights relating to the sale of personal information, targeted advertising or automated profiling; and
- complain to a relevant privacy or data protection authority.
These rights may be subject to exceptions. For example, we may need to retain or use information to comply with law, prevent fraud, protect the rights of others, maintain confidentiality or establish, exercise or defend legal rights.
To exercise a privacy right, please contact us at privacy@higherground.io.
Please provide enough information for us to understand your request and identify the relevant information. We may ask for additional information where reasonably necessary to verify your identity or authority.
Where permitted by applicable law, an authorised person may make a request on your behalf.
We will respond in accordance with applicable law. Where applicable law gives you a right to appeal a decision we make about a privacy request, you may appeal by contacting us at the same address and identifying your request as a privacy appeal.
We will not discriminate against you for exercising a privacy right available to you under applicable law.
9. Marketing
We may use your contact information to send you information about Higher Ground where permitted by law.
You may opt out of marketing communications at any time by using the unsubscribe option in the communication or by contacting us.
Opting out of marketing does not prevent us from contacting you about an assessment, recovery matter, engagement, payment, privacy request or other existing relationship with Higher Ground.
10. Questions, complaints and changes to this policy
If you believe personal information we hold about you is inaccurate or incomplete, or you have a question or concern about how we handle personal information, please contact us:
Higher Ground International LLC — contact@higherground.io
We take privacy concerns seriously and will try to resolve them promptly.
We may update this privacy policy from time to time to reflect changes to our business, services, technology, practices or legal requirements.
The current version will be published on our website and the date at the top of this policy will be updated when changes are made.
Where appropriate or required by law, we will take reasonable steps to bring material changes to the attention of affected individuals.