Privacy Policy

Our commitment to protecting your personal information and maintaining the highest standards of data security and privacy in all our investment services.

Effective Date: January 1, 2025 | Last Updated: January 1, 2025

Information We Collect

Our Town Capital collects information necessary to provide superior investment services while maintaining the highest standards of privacy protection. We collect information in the following categories:

Personal Information

  • • Name, address, phone number, and email address
  • • Social Security number and date of birth
  • • Investment experience and financial information
  • • Bank account and investment account details
  • • Professional and employment information

Financial Information

  • • Net worth and income documentation
  • • Investment objectives and risk tolerance
  • • Transaction history and account statements
  • • Credit information and financial references
  • • Tax identification and reporting requirements

Technical Information

  • • Website usage data and browsing patterns
  • • Device information and IP addresses
  • • Login credentials and access logs
  • • Communication preferences and history
  • • Security and authentication data

How We Use Your Information

We use the information we collect to provide exceptional investment services, maintain regulatory compliance, and protect the interests of our investors. Specific uses include:

Investment Services

  • • Portfolio management and optimization
  • • Investment opportunity evaluation
  • • Risk assessment and monitoring
  • • Performance reporting and analysis

Regulatory Compliance

  • • Know Your Customer (KYC) verification
  • • Anti-Money Laundering (AML) screening
  • • Accredited investor qualification
  • • Tax reporting and documentation

Communication

  • • Investment updates and reports
  • • Market commentary and insights
  • • Important notices and disclosures
  • • Customer service and support

Security & Protection

  • • Fraud prevention and detection
  • • Account security monitoring
  • • Identity verification processes
  • • System security and integrity

Information Sharing and Disclosure

Our Town Capital maintains strict confidentiality of client information and does not sell, rent, or trade personal information to third parties for marketing purposes. We may share information only in the following limited circumstances:

Required Disclosures

  • • Regulatory examinations and compliance requirements
  • • Court orders, subpoenas, and legal proceedings
  • • Tax reporting to relevant government authorities
  • • Anti-money laundering and suspicious activity reporting

Service Providers

  • • Qualified custodians and investment platforms
  • • Professional service providers (legal, accounting, audit)
  • • Technology vendors with strict confidentiality agreements
  • • Regulatory and compliance consultants

All third-party service providers are carefully vetted and required to maintain the same level of confidentiality and security that we maintain for your information.

Data Security and Protection

We employ institutional-grade security measures to protect your personal and financial information from unauthorized access, disclosure, alteration, or destruction:

Encryption

256-bit SSL encryption for all data transmission and storage

Access Controls

Multi-factor authentication and role-based permissions

Monitoring

24/7 security monitoring and incident response

Additional Security Measures

  • • Regular security audits and penetration testing
  • • Employee training and background checks
  • • Secure data centers with physical access controls
  • • Data backup and disaster recovery procedures
  • • Regular software updates and security patches
  • • Incident response and breach notification protocols

Your Privacy Rights

You have important rights regarding your personal information. We are committed to honoring these rights and providing you with control over your data:

Access and Correction

You have the right to:

  • • Review personal information we maintain
  • • Request corrections to inaccurate data
  • • Update your contact preferences
  • • Obtain copies of your information

Communication Preferences

You can control:

  • • Marketing communication preferences
  • • Report delivery methods and frequency
  • • Notification settings and alerts
  • • Third-party information sharing

Important Note

While we respect your privacy rights, certain information may be required to be retained for regulatory compliance, legal obligations, and ongoing investment management services. We will work with you to address your requests while maintaining our fiduciary and legal responsibilities.

Policy Updates and Changes

Our Town Capital reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, services, or applicable laws. We will notify you of material changes through:

Email Notification

Direct notification to your registered email address

Website Notice

Prominent display on our website and investor portal

Written Notice

Included with your regular investment reports

Your continued use of our services after any changes to this Privacy Policy constitutes acceptance of the revised terms. We encourage you to review this policy periodically to stay informed about our privacy practices.

Questions About Your Privacy?

We're committed to transparency and protecting your privacy. Contact us if you have questions about this policy or wish to exercise your privacy rights.