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Privacy Policy for AssetaPM
This Privacy Policy ("Policy") sets forth the terms and conditions under which AssetAPM ("Company", "we", "us", or "our") collects, processes, uses, maintains, protects, and discloses information, including personal data, provided by you ("User", "you", or "your") in connection with your access to and use of our websites, products, services, applications, or platforms (collectively, the "Services"). This Policy is intended for all Users, including without limitation, visitors, registered clients, and any individuals or entities interacting, directly or indirectly, with our Services.
1
Information We Collect
We may collect and process a range of information from or about you, including, but not limited to: name, physical address, email address, phone number, Social Security Number, date of birth, governmental identification, account numbers, transaction history, user credentials, device identifiers, IP addresses, geolocation data, browser information, usage statistics, financial information, and any other personal or sensitive data voluntarily submitted or generated through your use of the Services.
We may also collect automated technical information via cookies, web beacons, log files, and similar tracking technologies, including device type, operating system, browser type, pages viewed, referring URLs, timestamps, and activity logs.
2
Methods of Collection
Personal information may be collected directly from you through your account registration, submission of forms, requests for support or information, user-generated content, surveys, or correspondence with the Company.
Information may also be collected automatically through your interaction with our Services, or from third-party partners, service providers, or publicly available sources as permitted by law.
3
Use of Information
We may use the information collected for purposes including, but not limited to:
  • Performing our contractual obligations and providing Services (e.g., investment management, financial analytics, support)
  • Verifying User identity and preventing fraudulent activity
  • Complying with legal and regulatory obligations, including KYC, AML, CCPA, and GDPR requirements
  • Communicating regarding updates, notices, transactions, or marketing (subject to your consent where required by law)
  • Improving functionality, security, and user experience of our Services
  • Conducting analytics, research, audit, and business operations
Legal Basis for Processing
If you are in a jurisdiction that requires a legal basis for processing personal data (such as under the General Data Protection Regulation), we process your information pursuant to:
  • Consent expressly provided by you
  • Performance of a contract
  • Compliance with legal obligations
  • Protection of vital interests
  • Legitimate business interests, balanced against your privacy rights
Disclosure of Information
We may share your information with:
  • Affiliates, subsidiaries, and trusted third-party service providers who facilitate or support our Services
  • Regulators, governmental authorities, courts, or law enforcement agencies to comply with applicable laws
  • Successors in interest in the event of merger, acquisition, sale, reorganization, or other change of control
  • Other third parties only with your approval or as otherwise described herein or permitted by law
Security of Information
We implement comprehensive administrative, technical, and physical safeguards and controls designed to protect your information from unauthorized access, loss, misuse, disclosure, alteration, or destruction. Measures include, but are not limited to, data encryption, regular vulnerability assessments, firewall and network security protections, access controls, employee training, and policies governing incident response and business continuity.
Retention of Information
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with applicable legal and regulatory retention requirements, resolve disputes, enforce agreements, and as otherwise permitted or required by law.
International Data Transfers
Your information may be transferred to, stored, or processed in locations outside the jurisdiction in which you reside, including but not limited to the United States. In such cases, we ensure appropriate safeguards are in place to comply with cross-border data transfer requirements as applicable.
Your Rights and Choices
Depending on your jurisdiction, you may have rights regarding your personal information, including the right to access, correct, delete or restrict processing of your information, object to processing, and obtain a portable copy of your data. You may exercise these rights by contacting us using the contact information provided below; we reserve the right to take reasonable steps to verify your identity before fulfilling such requests.
Updates to this Privacy Policy
We reserve the right, at our sole discretion, to amend or update this Policy at any time to reflect operational, legal, or regulatory changes. Material changes will be prominently posted and, where required by law, we will obtain your consent or provide advance notice. Your continued use of the Services after any such changes constitutes your acceptance.

Contact Us
If you have questions regarding this Policy, wish to exercise your rights, or have concerns regarding your personal information or our privacy practices, please contact our Privacy Office at privacy@assetapm.com, or by mail at:
Privacy Office
AssetAPM
3551 Wilshire Way, Suite 900
Richardson, TX 75082
By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy.
Last updated: July 23, 2025