Effective Date: September 22, 2025

Last Revised: September 22, 2025

The Abraham Lincoln Canal Project (“we,” “us,” or “our”) is deeply committed to the privacy and security of individuals visiting our website and utilizing its services. This comprehensive Privacy Policy details how we collect, process, use, disclose, and safeguard your information, particularly within the context of our secure Investor Portal, and outlines your rights regarding your personal data. This policy has been drafted with due consideration for global privacy regulations, including but not limited to the General Data Protection Regulation (GDPR) of the European Union, and applicable U.S. federal and state privacy laws. Please read this policy thoroughly.

1. Scope and Applicability

This Privacy Policy applies to information we collect on our website located at [Your Website URL Here] (the “Site”), and in email, text, and other electronic messages between You and the Site. It does not apply to information collected by any third party not under our control.

2. Information We Collect and Lawful Basis for Processing

We collect various types of information for specified, explicit, and legitimate purposes. The lawful basis for processing is critical:

  • a) Information You Provide Voluntarily (Personal Data):
    • Source: Directly from you when you complete forms on our Site, especially the Investor Portal inquiry form.
    • Types: Full Name, Title/Position, Company/Organization, Corporate Email, Phone Number, Type of Organization, Anticipated Investment Range, and any optional message content.
    • Purpose: To verify your identity and qualification as a potential investor, to respond to your specific inquiries, to grant access to the Investor Portal, and to facilitate potential business engagement.
    • Lawful Basis:
      • Performance of a Contract/Pre-contractual Steps: To enter into or perform a potential investment agreement.
      • Legitimate Interests: To manage investor relations, prevent fraud, and maintain robust business operations.
      • Consent: For sending certain marketing communications, where distinct consent is provided.
      • Legal Obligation: For compliance with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations for verified investors.
  • b) Information Collected Automatically (Usage Data & Technical Data):
    • Source: As you navigate through the Site (e.g., via server logs, cookies, and analytics tools).
    • Types: IP address, browser type, operating system, device type, referring URLs, pages viewed, access times, and duration of visits.
    • Purpose: To monitor and analyze Site usage, improve Site functionality and security, diagnose technical problems, and optimize user experience.
    • Lawful Basis: Legitimate Interests: For maintaining and improving our Site’s performance, security, and user experience.

We are committed to data minimization, collecting only information relevant and necessary for the stated purposes.

3. How We Use Your Information

The information we collect is utilized to:

  • Present our Site’s content and functionalities effectively.
  • Verify and grant access to the secure Investor Portal.
  • Conduct necessary due diligence and legal compliance checks for potential investors.
  • Communicate with you regarding your inquiries, Project updates, and relevant opportunities (where consent is given or legitimate interest applies).
  • Maintain and improve the security and operational integrity of the Site and Project data.
  • Analyze user behavior to enhance user experience and Site features.
  • Comply with legal obligations and enforce our Terms of Service.

4. Disclosure and Sharing of Your Information

We will not sell, rent, or lease your personal information to third parties. We may disclose your information, under strict confidentiality agreements, only in the following circumstances:

  • To Our Affiliates: To our subsidiaries and entities involved directly in the Project’s development and operation, for purposes consistent with this Privacy Policy.
  • To Third-Party Service Providers: To contractors, service providers, and other third parties who perform services on our behalf (e.g., website hosting, data analysis, legal counsel, cybersecurity, compliance verification). These parties are contractually obligated to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • For Legal and Compliance Reasons: To comply with any court order, law, or legal process, including to respond to any government or regulatory request. This includes fulfilling our AML/KYC obligations.
  • Business Transfers: In the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Project’s assets, personal information held by us about our Site users may be among the assets transferred.
  • Protection of Rights: If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Project, our partners, or others.

5. International Data Transfers

Given the international nature of the Project and its potential investors, your information, including Personal Data, may be transferred to, stored, and processed in jurisdictions outside of your country of residence, including to the United States and other countries where our operational teams or service providers are located. These countries may have data protection laws that differ from those in your jurisdiction.

We implement robust safeguards to ensure your data is treated securely and in accordance with this Privacy Policy, regardless of its location. For transfers of Personal Data from the European Economic Area (EEA) or the UK, we rely on legally recognized mechanisms such as Standard Contractual Clauses (SCCs), or other legally valid transfer mechanisms, and implement additional security measures where necessary.

6. Data Security and Retention

We have implemented stringent organizational and technical measures designed to secure your personal information from accidental loss, unauthorized access, use, alteration, and disclosure. These include encryption, access controls, secure servers, and regular security audits. However, the transmission of information via the internet is never entirely secure. While we strive to protect your personal data, we cannot guarantee the absolute security of information transmitted to our Site. Any transmission of personal information is at your own risk.

We retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Specific retention periods are determined based on the nature of the data, the purpose of processing, and relevant legal obligations. Inquiry data from unqualified or non-progressing parties will be periodically deleted in accordance with our strict data retention schedule.

7. Your Data Protection Rights (GDPR and Other Applicable Laws)

Depending on your jurisdiction and the specific data protection laws applicable to you (e.g., GDPR for EEA residents, CCPA for California residents), you may have the following rights regarding your personal data:

  • The Right to Access: Request copies of your personal data.
  • The Right to Rectification: Request that we correct any information you believe is inaccurate or complete incomplete information.
  • The Right to Erasure (“Right to be Forgotten”): Request that we erase your personal data under certain conditions.
  • The Right to Restrict Processing: Request that we restrict the processing of your personal data under certain conditions.
  • The Right to Object to Processing: Object to our processing of your personal data under certain conditions.
  • The Right to Data Portability: Request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
  • The Right to Withdraw Consent: Withdraw your consent at any time where we relied on your consent to process your personal information.
  • The Right to Complain: Lodge a complaint with a supervisory authority if you believe we have infringed your data protection rights.

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided below. We will respond to your request within the legally required timeframe.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies (e.g., web beacons, pixels) to track activity on our Site and store certain information. Cookies are small data files stored on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site. For more detailed information on how we use cookies, please refer to our separate Cookie Policy [Link to your Cookie Policy, if applicable].

9. Changes to Our Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Revised” date. We encourage you to review this Privacy Policy periodically for any changes. Material changes will be communicated prominently.

10. Contact Information

For any questions, concerns, or requests regarding this Privacy Policy or your data protection rights, please contact our Data Protection Officer at: privacy@lincolncanal.org