Privacy Policy

At Pareto Technologies, LLC ("Pareto", "we", "us") we recognize the importance of protecting the privacy of our clients and of anyone who contacts us. This policy explains what personal information we collect, how we use it, who we share it with and how we protect it. It applies to our advisory clients (current and former), to prospective clients, and to visitors to our website and our member portal.

Information we collect

From clients and prospective clients, in the normal course of business:

• Information you give us in your advisory agreement, account onboarding forms and correspondence, such as your name, mailing address, email address, phone number, date of birth, taxpayer or government identification number, and income, net worth and other financial information.
• Information about your account and your transactions with us, such as your brokerage account number, account values, returns, fees and account status. We receive account data from your custodian, Interactive Brokers.

From users of our member portal (sign-in required):

• Your name, email address and, for some users, phone number.
• Your password, which we store only in hashed form.
• For clients: your brokerage account number(s) and the daily account values and returns we receive from Interactive Brokers.
• Comments you leave on documents.
• The legal name and mailing address you enter for your agreement. We store these encrypted and do not send them by email.
• Activity records, such as when a document was made available, viewed or signed, together with the IP address used.

From visitors to our public website: our web server keeps standard access logs (IP address, the page requested, and browser type). The public website does not use analytics, advertising cookies or tracking pixels, and it has no forms. If you email us, we receive whatever you include in your message.

How we use information

We use personal information to:

• provide, administer and report on our advisory services and your account;
• calculate and invoice fees;
• deliver documents to you and keep a record of that delivery;
• communicate with you;
• operate and secure our website and portal; and
• meet our legal and regulatory obligations.

We do not sell personal information, and we do not use it for advertising.

Who we share information with

We do not share nonpublic personal information about clients with unaffiliated third parties, other than our service providers, without first notifying you and obtaining your consent, unless the law requires otherwise.

We share information with service providers who help us run our business and service your account, and only as far as they need it to do so. These currently include:

• our custodian (Interactive Brokers);
• our email and office software provider (Google Workspace);
• our electronic-signature provider, which receives the signer's name and email address and keeps the signing record;
• our client-relationship management system (HubSpot), where we record our correspondence;
• our hosting provider (DigitalOcean);
• our auditors and legal counsel.

We may also disclose information:

• when required by law, such as in response to a subpoena;
• to satisfy a request from a regulator;
• to prevent fraud; and
• to governmental entities and others in connection with our obligations to prevent money laundering, including disclosures that may be required under the USA PATRIOT Act of 2001 and its regulations.

Cookies

Our member portal uses a single session cookie to keep you signed in. It is not used for tracking or advertising. Our public website does not set analytics or advertising cookies.

Confidentiality and security

• We restrict access to nonpublic personal information to the employees and agents who need it to provide our services.
• We maintain physical, electronic and procedural safeguards to protect it, including:
  • encrypted connections to our website and portal;
  • hashed passwords;
  • encryption of the most sensitive portal fields; and
  • regular backups held on systems we control.

Where information is kept

Our systems are hosted in the United States, and our service providers process information primarily in the United States. If you are located outside the United States, your information will be transferred to and processed in the United States, where data-protection laws may differ from those of your country.

How long we keep information

We keep personal information for as long as we need it to provide our services and to meet our legal, regulatory and record-keeping obligations. When we dispose of information we are not required to keep, we do so in a way that reasonably protects it from unauthorized access.

Former clients

This policy continues to apply to information about former clients.

Your choices

You may ask us to update or correct your information, or ask what information we hold about you, by contacting us at the address below. We will respond as required by applicable law.

Children

Our services and website are not directed to anyone under 18, and we do not knowingly collect information from children.

Changes to this policy

We may update this policy from time to time. The current version is always available on this page, with the date it was last updated.

Contact

Questions about this policy or your information: info@paretotechnologies.com

Pareto Technologies, LLC, a New Jersey limited liability company.