Privacy Policy

1. Introduction

NiolicFunds ("we," "our," or "us") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us in connection with our investment advisory services.

2. Information We Collect

2.1 Personal Information

We collect personal information that you voluntarily provide to us, including:

• Identity Information: Full name, date of birth, Social Security number, government-issued ID
• Contact Information: Email address, phone number, mailing address
• Financial Information: Bank account details, investment history, income, net worth, financial goals
• Investment Profile: Risk tolerance, investment experience, liquidity needs
• Employment Information: Employer, occupation, employment status
• Verification Documents: Passport, driver's license, utility bills, bank statements

2.2 Automatically Collected Information

When you use our website or services, we automatically collect:

• IP address and geographic location
• Browser type and version
• Device information and operating system
• Pages visited and time spent on our website
• Referral sources and exit pages
• Cookies and similar tracking technologies

2.3 Third-Party Information

We may obtain information about you from third parties, including:

• Credit reporting agencies
• Identity verification services
• Financial data providers
• Regulatory databases
• Social media platforms (when you interact with our content)

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Service Provision

• Providing investment advisory services
• Managing your investment accounts
• Processing transactions and payments
• Conducting risk assessments and suitability analyses
• Generating investment recommendations

3.2 Legal and Regulatory Compliance

• Verifying your identity (KYC procedures)
• Anti-money laundering (AML) screening
• Regulatory reporting requirements
• Tax reporting and documentation
• Compliance monitoring and record-keeping

3.3 Communication and Customer Service

• Responding to your inquiries and requests
• Providing account updates and statements
• Sending important notices and disclosures
• Customer support and technical assistance

3.4 Business Operations

• Website and service improvement
• Fraud detection and prevention
• Risk management and security monitoring
• Analytics and business intelligence
• Marketing and promotional communications (with consent)

4. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

4.1 Service Providers

We may share information with trusted third-party service providers who assist us in:

• Technology and hosting services
• Payment processing
• Identity verification and background checks
• Investment research and analytics
• Legal and accounting services

4.2 Legal Requirements

We may disclose your information when required by law or in good faith belief that such disclosure is necessary to:

• Comply with legal process or government requests
• Enforce our terms of service
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users or others
• Prevent fraud or other illegal activities

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

4.4 With Your Consent

We may share your information with your explicit consent or at your direction.

5. Data Security

We implement robust security measures to protect your personal information:

5.1 Technical Safeguards

• 256-bit SSL encryption for data transmission
• AES-256 encryption for data storage
• Multi-factor authentication
• Regular security audits and penetration testing
• Secure data centers with 24/7 monitoring

5.2 Administrative Safeguards

• Employee background checks and training
• Need-to-know access controls
• Regular security awareness training
• Incident response procedures
• Data breach notification protocols

5.3 Physical Safeguards

• Secured office facilities
• Locked filing cabinets for physical documents
• Visitor access controls
• Secure disposal of sensitive documents

6. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our website:

6.1 Types of Cookies

• Essential Cookies: Required for website functionality
• Performance Cookies: Help us understand how visitors use our site
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Used to deliver relevant advertisements (with consent)

6.2 Managing Cookies

You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our website.

6.3 Third-Party Analytics

We use Google Analytics and similar services to analyze website usage. These services may use cookies to collect and report website usage statistics.

7. Your Rights and Choices

You have the following rights regarding your personal information:

7.1 Access and Portability

• Request a copy of your personal information
• Receive your data in a portable format
• Access your account information through our client portal

7.2 Correction and Updates

• Correct inaccurate or incomplete information
• Update your contact and account preferences
• Modify your investment profile and goals

7.3 Deletion and Erasure

• Request deletion of your personal information (subject to legal requirements)
• Close your investment accounts
• Opt-out of marketing communications

7.4 Restriction and Objection

• Restrict the processing of your information
• Object to certain uses of your information
• Withdraw consent for optional data processing

8. Data Retention

We retain your personal information for the following periods:

• Active Accounts: For the duration of our business relationship
• Closed Accounts: Minimum 7 years as required by financial regulations
• Marketing Data: Until you opt-out or request deletion
• Website Analytics: Up to 26 months
• Legal Proceedings: Until resolution and appeal periods expire

We may retain certain information longer if required by law or for legitimate business purposes such as fraud prevention and regulatory compliance.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your residence. We ensure appropriate safeguards are in place:

• Standard Contractual Clauses (SCCs) for EU data transfers
• Adequacy decisions by relevant authorities
• Binding Corporate Rules where applicable
• Your explicit consent for specific transfers

10. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we discover that we have inadvertently collected such information, we will delete it promptly.

Parents or guardians who believe their child has provided personal information should contact us immediately.

11. California Privacy Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA):

11.1 Right to Know

• Categories of personal information collected
• Sources of personal information
• Business purposes for collection
• Categories of third parties with whom we share information

11.2 Right to Delete

Request deletion of your personal information, subject to certain exceptions.

11.3 Right to Opt-Out

We do not sell personal information. If this changes, California residents will have the right to opt-out.

11.4 Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA rights.

11.5 Authorized Agent

You may designate an authorized agent to make requests on your behalf.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. We will:

• Post the updated policy on our website
• Update the "Last Updated" date
• Notify you of material changes via email or website notice
• Obtain your consent for changes that materially affect your rights

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Contact Information

For privacy-related questions or to exercise your rights, please contact our Privacy Officer using the information above. We will respond to your request within 30 days of receipt.