Privacy Policy

Personal Identification Information: Name, email address, phone number, date of birth, Social Security Number or Tax Identification Number (for KYC/AML compliance), government-issued identification documents, and residential address.

Financial Information: Investment amounts, account balances, transaction history, cryptocurrency wallet addresses, and source of funds information required under our anti-money laundering (AML) program.

Technical Information: IP address, browser type, device identifiers, operating system, referring URLs, pages visited, and time spent on pages. This information is collected automatically through cookies and similar tracking technologies.

Communications: Emails, messages, and other communications you send to us, including support requests and feedback.

We use the information we collect to:

• Provide, operate, and maintain our investment advisory services
• Verify your identity and comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• Process transactions, deposits, and withdrawals on your behalf
• Send you account statements, performance reports, and material disclosures required by SEC regulations
• Communicate with you about your account, investments, and service updates
• Detect, prevent, and investigate fraud, security breaches, and illegal activity
• Comply with applicable laws, regulations, and regulatory obligations (including SEC, FINRA, and FinCEN requirements)
• Improve our services, website, and user experience

We process your personal data under the following legal bases:

• Contract: Processing necessary to perform our investment advisory agreement with you
• Legal Obligation: Processing required to comply with SEC, FINRA, FinCEN, and other applicable regulatory requirements
• Legitimate Interests: Processing necessary for fraud prevention, security, and improving our services
• Consent: Where you have explicitly consented to specific processing activities such as marketing communications

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

• Regulatory Authorities: We are required to share certain information with the SEC, FINRA, FinCEN, and other regulators as part of our compliance obligations
• Service Providers: We engage trusted third-party vendors (e.g., custodians, cloud hosting, KYC verification services) who process data solely on our behalf under strict confidentiality agreements
• Legal Requirements: We may disclose information if required by law, court order, or governmental authority
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction

We implement industry-standard security measures to protect your personal information, including:

• 256-bit AES encryption for data at rest and TLS 1.3 for data in transit
• Multi-factor authentication and role-based access controls
• Regular security audits and penetration testing
• Segregation of client assets from firm assets at qualified custodians
• Strict employee access controls and data handling policies

While we take all reasonable precautions, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

We use cookies, web beacons, and similar technologies to enhance your experience on our platform. These technologies help us:

• Maintain your session and authentication state
• Remember your preferences and settings
• Analyze usage patterns to improve our platform
• Detect and prevent fraudulent activity

You may control cookie settings through your browser. Disabling cookies may affect the functionality of certain features of our platform.

We retain your personal information for as long as necessary to:

• Maintain your active account and provide our services
• Comply with SEC Books and Records requirements (generally 5–7 years for most records)
• Comply with FINRA and FinCEN record-keeping obligations
• Resolve disputes and enforce our agreements

Following account closure, we retain certain records in accordance with applicable regulatory requirements.

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your data, subject to regulatory retention requirements
• Portability: Request transfer of your data to another service provider
• Opt-Out: Opt out of marketing communications at any time

To exercise any of these rights, please contact our Privacy Officer at privacy@ironcladcapital.tech. Please note that certain requests may be limited by applicable law and regulatory obligations.

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us immediately and we will take steps to delete such information.

Ironclad Capital LLC is based in the United States. If you access our services from outside the United States, your information may be transferred to and processed in the United States. By using our services, you consent to the transfer of your information to the United States, which may have different data protection laws than your country of residence.

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website with a new "Last Updated" date and, where required by law, by providing direct notice to you. Your continued use of our services after the effective date of any changes constitutes your acceptance of the updated policy.

If you have questions, concerns, or requests related to this Privacy Policy, please contact: