Privacy policy

Sparrilux Capital privacy policy

This privacy policy describes Sparrilux Capital's collection, use and sharing of personal information. As used in this privacy policy, "Sparrilux Capital" refers to Sparrilux Capital Brokerage Services LLC and the other Sparrilux Capital Hub companies that offer products and services available through this website and mobile applications where this policy appears.

Sparrilux Capital ("we") may offer products, services and digital offerings that may have a different or additional privacy policies made available to You if you choose to use those products, services or digital offerings. Some products and services available on our Digital Properties may have supplemental privacy policies that pertain to those products and services.

As used in this privacy policy ("policy"), personal information means information about an individual that is collected or maintained for business purposes and by which the individual can be identified. Please note that information by which an individual cannot be identified (for example, anonymous, de-identified, or aggregate information) is not considered personal information and therefore is not subject to this policy.

Please note that certain details of this policy may depend on whether you deal with us through an investment professional, directly as an individual investor, or whether Sparrilux Capital provides services to your employer or plan sponsor.

This policy is reviewed annually and updated to reflect any changes.

How and why we obtain and use personal information

Sparrilux Capital recognizes the importance of maintaining personal information about you and when we use it, we do so with respect for your privacy. We obtain and use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; operate and manage our business; and fulfill legal and regulatory requirements. Sparrilux Capital collects public and non-public personal information from customers and visitors from various sources. Some examples include:

• You or your representative on applications or forms (for example, when you interact with our customer service staff, and when you visit our websites or use our applications)
• You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our websites)
• You or your employer or plan sponsor if Strategic Assets Hub provides them with recordkeeping and/or employee benefits advisory services (for example, payroll, human resources, or benefits information)
• Transactional activity in your account (for example, trading history and balances)
• Other interactions with Sparrilux Capital (for example, discussions with our customer service staff, including telephone or chat, information you enter into our websites, or when you enroll in our authentication services)
• Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)
• Information from other third-party sources (for example, to verify your identity and to better understand your product and service needs)
• Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into Sparrilux Capital)

Please note that information by which you cannot be identified (for example, anonymous or aggregated information) is not considered personal information and therefore is not subject to this privacy policy.

How we protect information about you

We implement and maintain physical, administrative, technical and organizational measures designed to protect personal information and we regularly adapt these controls to respond to changing requirements and advances in technology.

At Sparrilux Capital, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you and to operate our business.

How we share information about you with third parties

Sparrilux Capital does not share or sell personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

• Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at Sparrilux Capital's direction)
• Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
• Other third-parties, with your consent or as directed by your representative (for example, if you request to transfer assets from another financial institution, or if you use an external aggregation website or service that you have provided permission to access your Sparrilux Capital financial account on your behalf)
• Other third parties whose products, services and investment offerings are made available through Strategic Assets Hub, and which you decide to utilize
• Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena)
• In connection with corporate business transactions, such as a merger or sale of a business.

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by Sparrilux Capital.

In addition, if you choose to use or indicate your interest in using a product, service or investment offering that is offered by a third party and made available through Sparrilux Capital, we may share personal information with that third party in connection with your use or interest of that product, service or investment offering.

Based on the nature of your relationship with Sparrilux Capital, we may exchange information with other third parties as described below:

• If Sparrilux Capital provides workplace services to your employer or plan sponsor, such as payroll, human resources or employee benefits advisory and/or recordkeeping services, Sparrilux Capital may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.
• If you conduct business with Sparrilux Capital through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
• If you transact business through Sparrilux Capital's life insurance companies, we may share personal information with and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may also share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.

How we provide information about you to our affiliates

We may provide personal information about you to various Sparrilux Capital corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services or for other business purposes.

If you interact with Sparrilux Capital directly as an individual investor (including joint account holders), we may provide certain information about you to Sparrilux Capital affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.

Where Sparrilux Capital provides services to you under an arrangement with your employer or plan sponsor, to the extent permitted by you or under our agreement with your employer or plan sponsor and as allowed by law, we may provide information about you to Sparrilux Capital's affiliates, such as our brokerage and insurance companies, for their use in marketing products and services.

Information collected from investment professionals' customers is not provided to Sparrilux Capital affiliates for marketing purposes, except with your or your representatives' consent and as allowed by law.

Your digital privacy

When you interact with us by using our websites, online services or applications (including mobile apps) that are owned and controlled by Sparrilux Capital Investments ("our digital offerings"), or via electronic communications, Sparrilux Capital manages personal information in accordance with all of the practices and safeguards described in this policy.

When you use or interact with us via our digital offerings, or interact with us via electronic communications, we (or our service providers on our behalf) may automatically collect technical and navigational and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving the design and functionality of our digital offerings and electronic communications, and personalizing your experience. Additionally, the following policies and practices apply when you are online.

Cookies and similar technologies

Sparrilux Capital and our third-party service providers may use cookies and similar technologies ("cookies") to support the operation of and maintain our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor's device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. Sparrilux Capital cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

Both Sparrilux Capital and third-party service providers we hire, such as Google and Meta, may use cookies and other technologies, such as web beacons, tags, or mobile device ID, in online advertising as described below. Most browsers and mobile devices offer their own settings to manage cookies. If you use those settings to refuse or delete cookies it may negatively impact your experience using our digital offerings, as some features and services on our digital offerings may not work properly. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences. Depending on your device and operating system, you may not be able to delete or block all cookies.

We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for our digital offerings, to improve the effectiveness of our online advertising and to understand more about the demographics of our users. You can learn more about Google's practices with Google Analytics by visiting Google's privacy policy. You can also view Google's currently available opt-out options.

Advertising on Sparrilux Capital Digital Offerings

Sparrilux Capital advertises on its own digital offerings (including our mobile applications), and when we do, we may use information about your relationship with us, such as the types of accounts you have, to tailor advertisements and communications about Strategic Assets Hub and third-party products and services that may be of interest to you.

We may also use third-party service providers to help us determine which Sparrilux Capital products and services may be of interest to you. These service providers may collect information about your activity on Sparrilux Capital digital offerings using cookies and other technologies to analyze, for example, pages visited, search engine referrals, browsing patterns and responses to advertisements and promotions. Such service providers may only collect and use such information for purposes specified by Sparrilux Capital and not for their own purposes.

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Advertising on Non-Sparrilux Capital Digital Offerings

Sparrilux Capital also advertises its products and services on platforms not affiliated with Sparrilux Capital. We partner with third-party advertising companies, such as Meta, to display these ads. These companies may use cookies and similar technologies to collect technical and browsing data, including your device type, browser type, IP address, pages visited, and timestamps.

Sparrilux Capital and these advertising partners may use this information, along with data about your relationship with Sparrilux Capital, to deliver relevant ads and measure campaign performance. These ads are tailored to your interests based on activity across Sparrilux Capital and other websites. This practice is known as "interest-based advertising."

You can opt out of receiving interest-based ads by clicking on the AdChoices icon in our ads and following the provided instructions. Additionally, you can manage your preferences through tools like the Digital Advertising Alliance (DAA) or Network Advertising Initiative (NAI):

• DAA WebChoices Tool
• NAI Consumer Opt-Out

For mobile devices, opt-out options are available at:

• YourAdChoices App
• NAI Mobile Opt-Out

Connecting with Sparrilux Capital on Social Media Platforms

Sparrilux Capital engages with users on social media platforms to foster interaction and collaboration. We may collect information that you provide through these platforms, such as opinions, photos, or your social media account details.

Please note that any content you share, such as pictures, personal information, or comments, is subject to the terms and privacy policies of the respective social media platforms. We encourage you to review their policies to understand your rights and responsibilities.

Third-Party Websites, Online Services, and Content

Sparrilux Capital’s digital offerings may include links to third-party websites or embedded content (e.g., videos). These third-party platforms operate independently, and this policy does not cover their privacy or security practices.

We recommend reviewing the privacy policies of third-party websites or services you interact with to understand their data collection and usage practices.

Children’s Privacy

Sparrilux Capital’s digital offerings are not intended for individuals under the age of 13. We do not knowingly collect personal information from children under 13. If a child under 13 has provided us with personal information, we request that a parent or guardian contact us to remove the data.

Additional Information

If you are a former customer, Sparrilux Capital will continue to protect your information as outlined in this policy.

To access or correct your account information, you can use your account statements, contact our customer service, or visit our digital platforms. For specific inquiries regarding your data, please refer to the contact information provided on your account documents or our official correspondence.

California Residents

This section aligns with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

Your Rights Under the CCPA

California residents have the following rights:

1. Right to Know: Access the categories and specific pieces of personal information collected about you.
2. Right to Delete: Request the deletion of your personal information, subject to exceptions.
3. Right to Correct: Request corrections to inaccurate personal information.
4. Right to Opt-Out: Opt-out of the sale or sharing of personal data.
5. Right to Limit Use: Restrict the use of sensitive personal information for specific purposes.
6. Non-Discrimination: Exercise your rights without facing discrimination.

Selling/Sharing of Personal Information

We DO NOT sell your personal information for payment or any other compensation. However, some of the ways we share your personal information with third parties on certain of our Websites may, under the CCPA, be considered to be a “sale” of personal information or “sharing” of personal information for “cross-context behavioral advertising” (as those terms are defined in the CCPA).

We engage third-party service providers, including marketing and advertising providers and social media platforms, to personalize your browsing experience on our Websites, provide targeted advertising services, and help us measure the effectiveness of our Websites and online advertising. When you visit our Websites, we and our providers collect certain information about your activity, including cookies and similar data stored on or collected from your browser or device. In some cases, our providers may combine this information with data about your activity on other unaffiliated websites or social media platforms to deliver ads to you when you visit those other sites. This sharing of information via cookies and similar methods, and the use of certain cookies by our providers, may be considered a "sale" of personal information or "sharing" for "cross-context behavioral advertising" under the CCPA.

California residents covered by the CCPA have the right to opt out of this "sale" or "sharing" of personal information. If we determine you are visiting the Website from California, you will see a "Do Not Sell or Share my Personal Information" link on the footer of the Website's homepage. To opt out, click the link and follow the prompts.

Note that Sparrilux Capital allows visitors to certain portions of our website (for example, the homepage at www.sparriluxcapital.org) to automatically exercise their right to opt out through the use of the Global Privacy Control (GPC) signal. If you’ve enabled the GPC signal in your browser, we will honor your request to opt out of this sale or sharing of personal information as communicated via the GPC signal. These opt-outs are device or browser-specific, so you will need to opt out again if you visit our website from a different device, change your browser settings, or clear your cookies.

In the 12 months preceding this notice, Sparrilux Capital “sold” and/or “shared” personal information for “cross-context behavioral advertising” with respect to California residents covered by the CCPA. We do not knowingly “sell” or “share” personal information of minors under 16 years of age for these purposes.

CCPA Exemptions

Certain types of personal information are exempt from the CCPA. These include:

• Personal information collected, processed, sold, or disclosed pursuant to federal laws such as the Gramm-Leach-Bliley Act (Public Law 106-102) or the California Financial Information Privacy Act.
• Medical information governed by laws such as the Confidentiality of Medical Information Act or protected health information collected by businesses under the Health Insurance Portability and Accountability Act (HIPAA).

Some businesses are also not subject to the CCPA, including:

• Businesses that do not operate in California.
• Businesses not organized for profit or financial gain.
• Businesses with annual gross revenue of $25,000,000 or less.

CCPA may refuse to honor a request to delete personal information in certain cases, such as when the information is necessary for:

• Completing a transaction or providing a service requested by the consumer.
• Ensuring security and integrity.
• Debugging errors or maintaining functionality.
• Exercising free speech or complying with legal obligations.

Please note that this summary does not cover all aspects of the CCPA and only highlights key points. There are additional exemptions and situations where a business is not required to honor a request to delete personal information.

Submitting a CCPA Request

To submit a CCPA request, please initiate your request through the communication options provided on our website. Review the CCPA exemptions to ensure your request is eligible.

You should generally receive a response within 45 days, although in some cases, an extension of 45 days may be required. We will notify you if an extension is necessary.

We will need to verify your identity before processing your request. You may need to confirm you are a California resident and provide any necessary information to verify your identity.

For more details on how to designate an authorized agent to make a CCPA request on your behalf, please refer to our website.

Between January 1, 2023 and December 31, 2023, Sparrilux Capital received 12 CCPA requests for disclosure of personal information and 18 requests for deletion of personal information. Responses to these requests were provided on average in 7.5 days.

Sparrilux Capital Funds Privacy Policy

Protecting your personal information is a priority for Sparrilux Capital Funds. We collect non-public personal information in the following ways:

• Information provided by you or your representative through applications or other forms.
• Information arising from your investments in or accounts with the Funds.
• Information we receive from a consumer reporting agency.

The Funds employ physical, electronic, and procedural controls to safeguard your information. Access is granted only to personnel who need it to provide services to you.

We do not disclose any non-public personal information about you, except as permitted by law. For example, the Funds have entered into arrangements with Sparrilux Capital Investments to provide investment management, distribution, and servicing of the Funds.

Even if you decide to close your account, the Funds will continue to adhere to the privacy policies as described here.

Please read the Sparrilux Capital Funds Privacy Policy in conjunction with the Privacy Policy for Sparrilux Capital Investments.

The Sparrilux Capital Funds Privacy Policy is provided on behalf of the Sparrilux Capital Investments family of funds, including those advised by Sparrilux Advisers LLC and Sparrilux Diversifying Solutions LLC.