1. Introduction

StockCircle Advisers, LLC and its parent company, StockCircle Holdings Corporation ("StockCircle," "we," "us," or "our") is committed to safeguarding the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our investment advisory services. By using our services, you consent to the practices outlined in this policy.

2. Information We Collect

We collect various types of information to provide, maintain, and improve our investment advisory services. The information we collect may include:

• Personal Identification Information: Includes but is not limited to your full name, residential address, mailing address, email address, phone numbers, Social Security number, and date of birth.
• Financial Information: Includes bank account numbers, credit card information, income details, investment holdings, and account balances.
• Investment Preferences and Risk Tolerance: Includes your investment objectives, risk tolerance, asset allocation preferences, and investment strategies.
• Transactional Information: Details of transactions executed on your behalf, including trade confirmations and account statements.
• Communications: Includes records of communications between you and us.
• Online and Technical Data: Includes IP addresses, browser types, operating systems, and usage data.

3. How We Use Your Information

• Service Provision and Management: To deliver and manage investment advisory services.
• Personalization: To customize our services according to your preferences.
• Compliance: To comply with applicable laws and regulations.
• Communication: To send you account updates and relevant information.
• Business Operations: To enhance our services and improve customer experience.

4. Information Sharing

We limit the disclosure of your personal information to:

• Service providers who assist in our operations
• Regulatory authorities when required by law
• Business transfers in case of merger or acquisition
• With your explicit consent

11. Contact Us

If you have any questions about this Privacy Policy, please contact us:

12. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the State of California, without regard to its conflict of laws principles. Any disputes arising from or related to this Privacy Policy shall be resolved in the courts of Orange County, California.