Privacy Policy

We Respect Your Privacy 

We greatly value the trust and confidence you place in us, and we are committed to protecting your  personal data. This Privacy Policy describes how we collect, process, use, share and secure the personal  information you provide. It also describes your choices regarding use, access, and correction of your  personal information.  

Personal Data 

This policy applies to personal data we may collect, process, and handle. For purposes of this statement,  "personal data" means information that: 

  • is about, or pertains to, a specific individual; and 
  • can be linked either directly or indirectly to that individual. 

Generally speaking, we collect and process personal data as follows: 

  1. from employees and independent contractors in the context of the employment or contractor  relationship, 
  2. from clients who wish to engage in advisory services or private placement securities transactions,  and 
  3. from customers and issuers (parties participating in securities transactions) as necessary to effect  transactions and as required by regulatory agency or legal requirements. 

Principles Protecting Individuals’ Privacy Notice and Choice 

We collect personal data from individuals as follows: 

  • We notify individuals about the personal data we collect from them, how we use it and how to  contact us with privacy concerns. All personal data is collected and processed with the express and  informed consent of the relevant individuals or is collected and processed pursuant to mandatory  legal requirements, including but not limited to those imposed by FINRA and the SEC. 
  • We provide such notice through this policy, our engagement letters or other similar documents,  instructions on personal data collection forms, and direct communication with individuals from  whom we collect personal data.
  • Consent for personal data to be collected, used, and/or disclosed in certain ways (including opt-in  consent for sensitive data) may be required in order for an individual to obtain or use our services.  Such consent is provided through our engagement letters, employment agreements, customer  identification forms, subscription agreements and other similar documents. 

Disclosures and Transfers 

We do not disclose an individual's personal data to third parties, except when one or more of the following  conditions is true: 

  • We have the individual's permission to make the disclosure. 
  • The disclosure is required by our broker-dealer firm, Growth Capital Services*, in order to effect a  private placement securities transaction or supervise the business activities of the firm’s registered  representatives or foreign associated persons. 
  • The disclosure is required by lawful request by public authorities, including to meet national  security, regulatory agency or law enforcement requirements. 
  • The disclosure is required by law or mandatory professional standards. 
  • The disclosure is reasonably related to the sale or other disposition of all or part of our business. • The information in question is publicly available. 
  • The disclosure is reasonably necessary for the establishment of legal claims. 
  • The disclosure is to persons or entities providing services on our or the individual's behalf (each a  "transferee"), consistent with the purpose for which the information was obtained, if the  transferee, with respect to the information in question, is subject to law providing an adequate  level of privacy protection or has agreed to provide an adequate level of privacy protection. 
  • We may supply personal data to a transferee for the purpose of verifying identification or suitability  for customers and issuers.  
  • We may transfer personal data from one jurisdiction to another. Privacy laws vary by jurisdiction,  and some may provide less or different legal protection than others. 

* All securities are offered through Growth Capital Services (“GCS”), member FINRA, SIPC. If you do not  wish to provide all of the information requested on GCS’ Customer Identification Form, or if your identity  cannot be adequately verified in accordance with federal requirements, GCS reserves the right to refuse  your participation in the transaction. You can review GCS’ Privacy Policy here.  

Data, Security, Integrity and Access 

We employ various physical, electronic, and managerial measures, including education and training of our  personnel, designed to reasonably protect personal information from loss, misuse or unauthorized access,  disclosure, alteration or destruction. Personal data collected or displayed through a website is protected in  transit by standard encryption processes. However, we cannot guarantee the security of information on or  transmitted via the Internet. 

We process personal data only for the limited and specific purpose for which it was originally collected or  authorized by the individual. To the extent necessary for such purposes, we take reasonable steps so that  personal data is accurate, complete, current, and otherwise reliable with regard to its intended use.  

An individual has the right to access personal data we hold about them. An individual may contact us using  the information below to correct, amend, or delete information where it is inaccurate. The individual will  need to provide sufficient identifying information, such as name, address, and birth date. We may request  additional identifying information as a security precaution such as possibly a national identifier (e.g. a Social  Security number). In addition, we may limit or deny access to personal information where providing such  access would be unreasonably burdensome or expensive in the circumstances, or where the rights of  persons other than the individual would be violated. In some circumstances, we may charge a reasonable  fee, where warranted, for access to personal information. 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in  accordance with applicable data protection laws. Notwithstanding the foregoing, we reserve the right to  keep any information in our archives that we deem necessary to comply with our legal and regulatory  obligations, resolve disputes and enforce our agreements. 

Data Rights 

Your rights under relevant data protection laws are complex. We have attempted to summarize your rights  herein, but not all details can be included in these summaries. Accordingly, you should read the relevant  laws and guidance from the regulatory authorities for a full explanation of these rights. 

You have the right to consent to whether we collect any personal data from you, and whether or not we  process your personal data. Where we do process or share personal data, you have the right to know the  purposes of the processing, the categories of personal data concerned, and any recipients of your personal  data.  

You have the right to have any inaccurate personal data about you corrected and, taking into account the  purposes of the processing, to have any incomplete personal data about you completed. 

To the extent not inconsistent with our legal and regulatory obligations, you may have the right to the  erasure of your personal data. 

You may have the right to restrict or object to the processing of your personal data under certain  circumstances, subject to external legal and regulatory requirements. If you object, we will cease to process  your personal information unless we can demonstrate compelling legitimate grounds for the processing  which override your interests, rights and freedoms, or the processing is for the establishment, exercise or  defense of legal claims. To the extent that the legal basis for our processing of your personal information is  consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness  of processing before the withdrawal. 

You may exercise any of your rights in relation to your personal data by written notice to us via email  directed to


Accountability and Enforcement 

You may file a complaint in connection with our processing of your personal data using the contact  information below. We will take appropriate steps to address any adverse effects and to promote future  compliance. Personnel who violate our privacy policies will be subject to disciplinary action or termination.  


We may amend this policy from time to time by posting a revised policy on this website. If we amend the  policy, the new policy will apply to personal data previously collected only insofar as the rights of the  individual affected are not reduced.  

Contact Information 

For further information, questions, access requests, or any other issues, please contact: Name 



Mailing address 

Email: email address 

Phone: phone number