Privacy Policy

Information We Collect

Personal Information

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

• Name, email address, and phone number
• Investment experience and financial information
• Accredited investor status and documentation
• Information provided during consultation forms and calls
• Correspondence and communications with our team

Automatically Collected Information

We automatically collect certain information when you visit our website:

• IP address and general location information
• Browser type, device type, and operating system
• Pages visited, time spent on pages, and navigation patterns
• Referral sources and search terms used to find our website

How We Use Your Information

We use the information we collect to:

• Provide investment advisory services and portfolio management
• Assess your eligibility and suitability for our investment strategies
• Communicate with you about our services, market updates, and account information
• Comply with legal and regulatory requirements
• Improve our website, services, and client experience
• Conduct research and analysis for investment purposes

Information Sharing and Disclosure

We may share your information in the following circumstances:

Service Providers

We work with trusted third-party service providers who assist us in operating our business, including:

• Custodians and prime brokers for account administration
• Technology providers for CRM, website hosting, and analytics
• Legal, accounting, and compliance professionals

Legal Requirements

We may disclose your information when required by law, regulation, or legal process, including:

• SEC, FINRA, or other regulatory examinations and investigations
• Court orders, subpoenas, or other legal proceedings
• Anti-money laundering and suspicious activity reporting

Business Transfers

If we undergo a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of sensitive data in transit and at rest
• Access controls and multi-factor authentication
• Regular security assessments and employee training
• Compliance with industry-standard security frameworks

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our website:

Types of Cookies

• Essential Cookies: Required for website functionality
• Analytics Cookies: Help us understand website usage patterns
• Marketing Cookies: Enable personalized content and advertising

You can control cookie settings through your browser preferences. Disabling certain cookies may affect website functionality.

Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

• Access to the personal information we hold about you
• Correction of inaccurate or incomplete information
• Deletion of your personal information in certain circumstances
• Restriction or objection to certain processing activities
• Data portability in machine-readable format

To exercise these rights, please contact us using the information provided below.

Data Retention

We retain your personal information for as long as necessary to provide our services and comply with legal obligations. Specific retention periods include:

• Client records: 6 years after account closure (as required by investment advisor regulations)
• Marketing communications: Until you unsubscribe or opt-out
• Website analytics: 24-38 months depending on the data type

International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place when transferring personal information internationally, including:

• Standard contractual clauses approved by relevant authorities
• Adequacy decisions by regulatory bodies
• Other legally compliant transfer mechanisms

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes by:

• Posting the updated policy on our website with a new "Last updated" date
• Sending email notifications to registered users
• Providing notice through our client portal or other communication channels

Your continued use of our services after changes become effective constitutes acceptance of the updated Privacy Policy.