Privacy Policy
This Privacy Policy explains how PRAGMA HOLDINGS AZ CORP (“Pragma”, “we”, “us”) collects, uses, and protects personal information submitted through this website. Pragma is a United States investment and holding company, with its team based in Boston, Massachusetts. The operating entity is PRAGMA HOLDINGS AZ CORP, a corporation incorporated in Delaware and authorized to do business in Massachusetts. Its principal business activities take place in Massachusetts.
1. Scope
This policy applies to information collected through this website, including the opportunity submission form and the general enquiry form, and to correspondence that follows from those submissions. It does not apply to third-party websites we may link to.
2. Information we collect
- Information you give us. Name, company, email address, telephone number, and the details you choose to include about an opportunity — asset type, market, ticket size, stage, the structure you are seeking, and your description.
- Correspondence. Messages, documents, and notes exchanged with us after an initial submission.
- Technical information. Standard server and device information such as IP address, browser type, and pages viewed, where our hosting provider records it for security and reliability purposes.
Please do not send confidential or privileged material with a first submission. If confidentiality is required, tell us and we will discuss an appropriate agreement first.
3. Why we use it
- To read, screen, and respond to an opportunity or enquiry.
- To conduct due diligence, including verification of counterparties and, where relevant, know-your-customer and anti-money-laundering checks.
- To communicate with you about a submission and to negotiate, document, and administer any resulting transaction.
- To keep records required for legal, tax, audit, and regulatory purposes.
- To maintain the security and integrity of this website.
We do not sell personal information, and we do not use submissions to build marketing lists or send unsolicited promotional email.
4. Legal basis and consent
Where you submit a form, you do so voluntarily and you consent to our processing the information for the purposes described above. We also process information where it is necessary to pursue a transaction you have approached us about, to comply with law, or to protect our legitimate interests in assessing and documenting investments.
5. Sharing
We may share information with professional advisers acting for us — counsel, accountants, tax advisers, and diligence providers — and with service providers who host our website, email, and document systems. We may also share information where required by law, court order, or a lawful request from a government or regulatory authority, or where necessary to establish or defend legal claims. Providers’ processing is governed by the applicable service agreements, settings, and privacy terms. If you allow optional analytics, information will also be transmitted to Google. See Section 9 for Google Analytics.
6. Retention
We retain business correspondence for as long as reasonably necessary to handle enquiries and meet applicable legal obligations. The website does not maintain a separate archive of message contents.
When you allow Google Analytics, analytics data is retained within Google Analytics under Google’s applicable retention rules and the settings of our property. We do not export analytics data or maintain a separate analytics database or archive. Retention controls for user-level and event-level data do not apply to standard aggregated reports. Business email and hosting records have separate retention arrangements; Google Analytics settings do not control their retention.
7. Security
We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Email in particular is not a secure channel; treat it accordingly.
8. Your choices and rights
You may ask us to confirm what personal information we hold about you, to correct inaccurate information, or to delete information we no longer need to retain. You may withdraw consent to further contact at any time. Depending on where you live, you may have additional statutory rights — including, for residents of certain US states, rights to know, delete, correct, and to opt out of sale or sharing of personal information. We do not use enquiry submissions for cross-context behavioural advertising. We will not discriminate against you for exercising any right.
To make a request, contact us using the details in Section 12. We may need to verify your identity before acting on a request.
9. Cookies and analytics
This website is a static informational site. This Website offers optional Google Analytics 4 to measure its use. Analytics is disabled until you allow it using the analytics controls. Fonts are served with this website, without requests to Google Fonts. Our website hosting provider, GoDaddy, processes online form submissions and relays them to our designated email address. Our form handler does not save message contents in a website database. Temporary technical records contain submission fingerprints and pseudonymous network identifiers to prevent duplicate mail and abuse; records older than 24 hours are removed during subsequent new submission processing and may remain longer while the site is inactive. Copies of submissions may remain in our email system and in our hosting provider’s operational logs under their retention policies. Basic server logs may be retained by our hosting provider for security and diagnostics.
You can allow or reject optional analytics and use Cookie settings in the footer to change that choice. We remember this preference in your browser for up to 180 days. If browser storage is unavailable, the choice lasts only for the current page. Analytics loads only after permission; rejecting analytics will not prevent enquiries or use of the Website. A Global Privacy Control signal will keep optional analytics disabled. Do Not Track signals alone will not change the analytics preference.
Our analytics integration measures page views and form submissions accepted by our mail relay, using information such as device and browser characteristics, approximate location, and cookie identifiers. It excludes names, email addresses, phone numbers, and form contents from analytics events. Our integration disables advertising personalization and Google signals, and does not send advertising events. We do not send form fields to Google. Withdrawing analytics permission stops further collection on this Website and removes accessible Google Analytics cookies; it does not automatically delete data already received by Google.
When analytics is enabled, information will be transmitted to Google. Google’s processing is governed by the applicable service terms, data-sharing settings, and privacy policies. See How Google uses information from sites or apps that use our services and Google’s Privacy Policy.
10. Children
This website is directed to businesses and professional counterparties. It is not intended for anyone under 18, and we do not knowingly collect information from children.
11. International transfers
We are based in the United States and information submitted to us is processed there. If you contact us from outside the United States, you understand that your information will be transferred to and processed in the United States, where data protection law may differ from that of your own jurisdiction.
12. Contact and changes
Questions or requests about this policy may be sent to info@investpragma.com. Where a postal address is required for a formal request, we will provide it on request.
We may update this policy from time to time. The version published on this page is the current version. Where required by applicable law, we will provide additional notice or obtain consent before material changes take effect.