Privacy Policy

1. Scope of This Privacy Policy

This Privacy Policy applies to personal information that Best Holdings receives through or in connection with the Site; inquiries and communications with Best Holdings; prospective, current, and former business relationships; counterparty, supplier, mandate, and other commercial evaluations; transaction and diligence processes; meetings, introductions, referrals, and professional relationships; and other interactions in which Best Holdings determines the purposes and means of handling personal information.

This Privacy Policy does not replace the terms of any confidentiality agreement, mandate agreement, definitive transaction agreement, data-room arrangement, diligence protocol, or other written agreement applicable to a particular relationship. Where a separately executed agreement or specific notice governs the handling of particular information, that agreement or notice applies according to its terms and controls to the extent of any inconsistency with this Privacy Policy.

This Privacy Policy does not apply to websites, platforms, or services operated independently by third parties.

2. Personal Information We Collect

The personal information we collect depends on the nature of your interaction with Best Holdings and the legitimate requirements of the relevant relationship or transaction.

Information You Provide Directly

We may collect information that you provide directly to us, including:

• name, business email address, telephone number, professional title or role, company, institution, or organization, and country or jurisdiction;
• correspondence, communications, inquiry details, meeting information, and relationship information; and
• documents or other materials that you choose or are requested to provide.

You should not submit government-issued identification, banking information, payment instructions, confidential transaction materials, or other sensitive information through a general website communication channel unless Best Holdings has requested the information and an appropriate method of transmission has been established.

Professional and Organizational Information

In the course of evaluating or managing a business relationship, we may collect information concerning your professional position and responsibilities; the organization you represent; your authority to act for that organization; ownership, control, or beneficial-ownership information where relevant; mandate or representation status; professional affiliations; business relationships; and information reasonably necessary to understand your role in a proposed or existing engagement.

Transaction and Diligence Information

Where a relationship advances beyond an initial inquiry, Best Holdings may collect additional information appropriate to the nature, value, jurisdiction, complexity, and risk of the engagement. This may include information relating to:

• identity and identity verification, authority, representation capacity, beneficial ownership, and control;
• counterparties, transaction participants, and the purpose and nature of a proposed relationship;
• asset, product, source, origin, provenance, ownership, logistics, custody, or other transaction context;
• sanctions, politically exposed person, adverse-media, anti-fraud, anti-corruption, responsible-sourcing, or other compliance screening;
• financial capability, transaction readiness, banking, settlement, payment participants, and account ownership; and
• legal, regulatory, commercial, reputational, technical, and other information contained in diligence materials, transaction documents, professional reports, or supporting records.

The type and depth of information requested will vary. Best Holdings seeks to calibrate diligence to the legitimate requirements of the specific relationship or transaction rather than collect information indiscriminately.

Technical and Site Usage Information

The hosting and security infrastructure used to deliver the Site may process technical request information that is necessary to operate, protect, and transmit the Site.

Best Holdings uses built-in, cookie-free analytics for basic, privacy-oriented Site measurement. This analytics functionality provides anonymized metrics such as pageviews, daily unique visitors, referring sources, UTM parameters, pages viewed, country, device type, browser, operating system, bounce rate, session duration, and entry or exit pages. This analytics functionality does not use cookies or persistent identifiers and is designed not to track, collect, or store information that identifies a person. Best Holdings does not receive directly identifying visitor information through This analytics functionality.

3. Sources of Personal Information

Best Holdings may obtain personal information from you directly; the company, institution, or organization you represent; counterparties, mandate holders, principals, suppliers, buyers, sellers, or other transaction participants; professional advisers, legal counsel, accountants, financial institutions, or other service providers; persons who introduce or refer you or your organization to Best Holdings; screening, verification, diligence, compliance, or information-service providers; government, corporate, licensing, sanctions, court, or other public records; professional networks and publicly available business sources; and Site infrastructure, hosting, security, or analytics technologies.

We may combine information received from different legitimate sources where reasonably necessary to evaluate a relationship, verify information, conduct diligence, manage a transaction, or maintain accurate records.

4. How We Use Personal Information

Best Holdings may use personal information to:

• operate, administer, maintain, secure, and understand the Site;
• respond to inquiries and communications and manage business relationships;
• evaluate prospective commercial relationships and identify and verify individuals, entities, roles, ownership, control, and authority;
• assess counterparty, supplier, mandate, transaction, sanctions, fraud, financial-crime, responsible-sourcing, and other risks;
• conduct or coordinate diligence and evaluate the legitimacy, structure, and executability of proposed transactions;
• communicate with counterparties, advisers, service providers, and other authorized participants and coordinate documentation, commercial processes, and transaction execution;
• verify banking, settlement, payment, custody, logistics, or other transaction information where relevant;
• prevent, detect, investigate, and respond to fraud, impersonation, security incidents, misconduct, or unlawful activity;
• protect Best Holdings, its counterparties, its relationships, and other persons; administer contractual obligations; and establish, exercise, or defend legal rights;
• maintain appropriate business, transaction, compliance, security, and evidentiary records;
• comply with applicable law, legal process, regulatory requirements, contractual obligations, and legitimate institutional diligence requirements; and
• obtain professional advice and perform other activities reasonably necessary for a purpose disclosed to you or compatible with the context in which the information was collected.

Best Holdings operates through selective, relationship-driven engagements and does not use personal information as the basis for unrelated mass-market consumer advertising.

5. Sensitive and Diligence-Related Information

Certain information received during a diligence or transaction process may be considered sensitive under applicable law or may otherwise warrant heightened protection because of its nature. This can include government-issued identification information, financial or banking information, beneficial-ownership information, transaction records, compliance information, or other information used to establish identity, authority, legitimacy, source, payment integrity, or transaction readiness.

Best Holdings seeks to collect and use such information only where reasonably relevant and proportionate to the purpose for which it is requested. Sensitive or diligence-related information may be used for identity and authority verification; counterparty and transaction qualification; sanctions, anti-money laundering, anti-fraud, anti-corruption, responsible-sourcing, or other compliance review; source, provenance, ownership, or control verification; payment and settlement verification; security and fraud prevention; transaction execution; legal or regulatory compliance; and preservation or defense of legal rights.

Best Holdings does not use diligence-related information to infer personal characteristics unrelated to the legitimate commercial, compliance, security, or legal purpose for which the information was obtained.

6. How We Disclose Personal Information

Best Holdings does not disclose personal information indiscriminately. Disclosure is generally limited to persons or organizations with a legitimate role in the applicable business, legal, diligence, operational, or transaction process.

Service Providers

We may use service providers that support website hosting and technology, email and communications, information security, document management, screening and verification, professional research, data storage, analytics, and other operational functions. Service providers receive information only as appropriate to the services they perform and are expected to handle information in accordance with applicable obligations.

Professional Advisers

We may disclose information to lawyers, accountants, consultants, technical advisers, compliance specialists, auditors, insurers, or other professional advisers where reasonably necessary to obtain advice, perform diligence, protect rights, or support a legitimate engagement.

Counterparties and Transaction Participants

Where relevant to a bona fide engagement, information may be disclosed to appropriately authorized participants such as buyers or sellers; principals or mandate holders; suppliers or asset owners; mines, exporters, traders, or commodity counterparties; banks or other financial institutions; refineries, assayers, vaults, custodians, or inspection providers; logistics or insurance providers; escrow, settlement, or other transaction service providers; financing sources; and other qualified participants whose involvement is reasonably necessary to evaluate, structure, document, finance, or execute a transaction.

Any such disclosure is subject to the context of the engagement, legitimate need, applicable confidentiality arrangements, and other protections considered appropriate by Best Holdings.

Affiliates, Ventures, and Transaction Entities

We may disclose information to an affiliate, joint venture, special-purpose vehicle, project entity, or other entity through which Best Holdings participates in or administers an applicable relationship, subject to the governing arrangements of that entity or engagement.

Legal and Protective Disclosures

We may disclose personal information where we reasonably believe disclosure is necessary or appropriate to comply with applicable law, regulation, legal process, court order, or governmental request; respond to lawful requests from regulatory, law-enforcement, or other public authorities; investigate or prevent fraud, corruption, sanctions violations, security incidents, theft, misuse, or other potentially unlawful conduct; establish, exercise, or defend legal claims; enforce agreements or protect contractual rights; protect the rights, property, security, or legitimate interests of Best Holdings or another person; or preserve information relevant to an investigation, dispute, audit, litigation hold, or other legal process.

Corporate Transactions

Personal information may be disclosed in connection with an actual or proposed merger, acquisition, financing, restructuring, sale of assets, reorganization, succession, or similar corporate transaction, subject to appropriate confidentiality and legal protections.

7. Website Analytics, Cookies, and Tracking Technologies

At launch, Best Holdings does not deploy third-party advertising pixels, third-party analytics scripts, retargeting tools, or other third-party tracking scripts on the Site.

The Site uses built-in, cookie-free analytics that do not generate persistent identifiers. The analytics reports provided to Best Holdings are anonymized. Best Holdings uses this functionality only to understand basic Site activity and performance, including aggregate traffic, pages viewed, referral sources, countries, device categories, browsers, operating systems, and similar usage metrics.

Because Best Holdings does not deploy non-essential analytics or advertising cookies or third-party tracking scripts at launch, the Site does not use a cookie consent banner for this cookie-free analytics functionality. If Best Holdings later adds a service, script, pixel, or other technology that uses non-essential cookies or otherwise creates a consent or opt-out obligation under applicable law, we will update this Privacy Policy and implement appropriate notice and choice mechanisms as required.

Some browsers offer a "Do Not Track" signal. Because there is no uniform industry standard governing how all websites should respond to such signals, the Site does not currently respond to browser Do Not Track signals. Where applicable law requires Best Holdings to recognize a legally valid privacy preference or opt-out signal, Best Holdings will process that signal as required by applicable law.

8. Sale of Personal Information and Behavioral Advertising

Best Holdings does not sell personal information in exchange for monetary consideration. Best Holdings does not operate the Site for consumer-focused cross-context behavioral advertising or targeted advertising based on an individual's activity across unrelated businesses or services, and Best Holdings does not deploy third-party advertising pixels for that purpose at launch.

If our practices change in a manner that creates a notice, consent, or opt-out right under applicable privacy law, we will update this Privacy Policy and provide any legally required mechanism.

9. Data Retention

Best Holdings retains personal information for periods reasonably necessary to fulfill the purposes for which the information was collected and to satisfy legitimate business, contractual, compliance, evidentiary, security, and legal requirements. Retention periods vary according to the nature of the information and relationship.

Ordinary Site and inquiry information may be retained for a shorter period where no continuing relationship develops. Business relationship and correspondence records may be retained while the relationship remains active and for a reasonable period afterward. Diligence, counterparty, compliance, payment, and transaction records may be retained for longer periods where necessary to reconstruct material decisions, satisfy institutional requirements, demonstrate compliance, manage risk, or protect legal rights.

Information may also be retained for additional periods where required or justified by law, contract, audit, investigation, dispute, litigation hold, regulatory request, security concern, or counterparty requirement. When information is no longer reasonably required, Best Holdings may delete, anonymize, archive, or otherwise dispose of it in accordance with applicable requirements and operational practices.

A request to delete personal information does not require Best Holdings to delete information that applicable law permits or requires us to retain.

10. Data Security

Best Holdings maintains administrative, technical, organizational, and physical measures designed to protect personal information in a manner appropriate to the nature and sensitivity of the information and the context in which it is handled.

Measures may include access controls, authentication, secure communication practices, controlled disclosure, document-management procedures, vendor controls, transaction verification, recordkeeping, and other safeguards appropriate to the relevant activity. Access to sensitive information is intended to be limited to persons with an appropriate role and legitimate need to know.

No method of transmission, storage, or information security can be guaranteed to be completely secure. Best Holdings therefore cannot warrant absolute security. If you believe information provided to Best Holdings may have been compromised or that an unauthorized person is using Best Holdings' identity or communication channels, please contact us promptly.

11. International Processing and Cross-Border Relationships

Best Holdings is based in the United States and engages with counterparties, advisers, service providers, and other commercial participants across multiple jurisdictions. As a result, personal information may be accessed, transferred, stored, or processed in the United States or another jurisdiction different from the jurisdiction in which the information was originally collected. Privacy and data-protection laws may differ among jurisdictions.

Where applicable law requires particular safeguards for an international transfer or processing arrangement, Best Holdings will seek to implement measures appropriate to the circumstances and applicable requirements. Nothing in this Privacy Policy should be interpreted as representing that any particular foreign privacy regime applies to Best Holdings or to every interaction with an individual located in another jurisdiction.

12. Your Privacy Rights and Choices

Depending on where you reside and the law applicable to the relevant processing, you may have rights concerning your personal information. Those rights may include the right to request information about personal information Best Holdings maintains about you; access to personal information; correction of inaccurate information; deletion of certain personal information; a copy or transfer of certain personal information; restriction of or objection to certain processing; withdrawal of consent where processing is based on consent; or an opt-out of certain sale, sharing, targeted-advertising, or profiling activities where such rights apply.

These rights are not absolute and may be subject to legal exceptions. For example, Best Holdings may be permitted or required to retain information necessary for compliance, security, fraud prevention, contractual obligations, transaction records, legal claims, investigations, audits, dispute resolution, or other lawful purposes.

We may take reasonable steps to verify your identity, authority, and jurisdiction before responding to a request. Where permitted by law, we may request additional information reasonably necessary to prevent fraudulent or unauthorized requests. If an authorized agent submits a request on your behalf, we may require evidence of the agent's authority and may independently verify the request with you where permitted.

Best Holdings will not discriminate against an individual for exercising a privacy right where applicable law prohibits such discrimination.

To submit a privacy request, contact info@bestholdings.com and identify the request as a Privacy Inquiry.

13. Information Concerning Other Individuals

If you provide Best Holdings with personal information concerning another individual, you should provide that information only where you have lawful authority or another legitimate basis to do so. You are responsible for ensuring that your disclosure to Best Holdings does not violate an applicable confidentiality obligation, privacy requirement, contractual restriction, or other legal duty.

Best Holdings may request evidence of authority or may decline to use information where the circumstances do not provide sufficient confidence that it was obtained or disclosed appropriately.

14. Third-Party Websites

The Site may contain links to websites, platforms, publications, databases, or services operated by third parties. Best Holdings does not control the privacy, security, data handling, or other practices of those third parties.

This Privacy Policy applies only to Best Holdings' handling of personal information and does not apply to information you provide directly to a third party. You should review the privacy practices of a third-party website or service before providing personal information to it.

15. Children's Privacy

The Site is intended for professional, commercial, and institutional audiences and is not directed to children. Best Holdings does not knowingly collect personal information through the Site from children under 13.

If we learn that personal information from a child under 13 has been collected through the Site without appropriate authorization, we will take reasonable steps to delete the information where required by law.

16. Changes to This Privacy Policy

Best Holdings may update this Privacy Policy from time to time to reflect changes in our business activities, Site functionality, information practices, legal requirements, or other circumstances. When we revise the Privacy Policy, we will update the effective date shown at the top of this page.

Where required by applicable law or appropriate in light of the nature of a change, we may provide additional notice. You should review this Privacy Policy periodically for the most current information regarding our privacy practices.

17. Contact Us

Questions, concerns, or requests concerning this Privacy Policy or Best Holdings' handling of personal information may be directed to:

Best Holdings LLC
San Francisco, California | info@bestholdings.com | bestholdings.com