Introduction

This Privacy Policy (“Policy”) is for the use of any current clients and/or prospective clients of Fountaindale (“you” or “your”). The Privacy policy applies to personal information that is both public and non-public which Fountaindale both collects and controls during the course of its business activities, including such information we collect on our website (“Site”). Fountaindale LLC (“Fountaindale” or the “Advisor”) is a Registered Investment Advisor (“RIA”). As an advisor, we are required to safeguard the use of personal information of that we collect and control. Fountaindale (here also referred to as "we", "our" and "us") protects such information. Specifically, through the use of the Policy and tools for its implementation, we aim to ensure that your information is used for proper business purposes related to our relationship with you. Including with private companies and natural persons, Fountaindale does not—and will not—sell, trade, or exchange your personal information to anyone. Fountaindale does not even provide such information, except for defined purposes we have discussed below. In addition to informed consent that you give to Fountaindale to process your personal information, Fountaindale may have one or more of the following legally-sanctioned reasons to process your personal information, including that processing is necessary for: fulfilling a contractual obligation; complying with applicable regulations, rules, and laws; or Fountaindale’s legitimate interest and/or that of a third party. Please read this Policy, which Fountaindale sets forth below, for more details.

Why Fountaindale has a Policy

To maintain and provide services for your account(s), Advisors like Fountaindale must share some of your personal information. Laws at both the Federal and State level give you rights to limit some of this sharing. These laws also require RIAs to tell those we provide services to, or may provide services to, how we share, protect, and collect personal information through our Site and other sources discussed below.

Specifically, the Policy describes how we collect and use your personal information at various points during our relationship with you, including during and after a business relationship with us. It describes your privacy rights under applicable laws, the purposes for processing the information, and how we protect your information. To the extent the General Data Protection Regulation (“GDPR”) applies to the Policy, it also describes how we define personal information, nonpublic information, and personal data.

How Your Information is Shared and Limitations to Sharing

Fountaindale generally shares Client personal information pursuant to the delivery of its services, as do all financial companies over the course of business. Fountaindale restricts access to all current and former Clients’ nonpublic information as described above to employees and affiliated/nonaffiliated entities who need to know such information with respect to the Client's engagement of Fountaindale for our services. In that regard, Fountaindale may disclose the Client’s information: where required to do so by regulatory or legal procedures or rule; and where permitted within the ambit of federal and state privacy regulations; and to those who are unaffiliated with Fountaindale, including, but not limited to the client’s other service providers that may be recommended or engaged by Fountaindale with respect to the Client's engagement with Fountaindale.

With respect to delivering Fountaindale’s services, including with a nonaffiliated third-party service provider (e.g., a custodian, recorder keeper, broker-dealer, account aggregator, &c.), both Clients and/or prospective clients are deemed to have automatically authorized Fountaindale to share any information contained in any document completed by a Client and/or prospective client to Fountaindale.

To the extent U.S. Federal laws applies to personal nonpublic information, you have the right to limit affiliates’ information sharing for marketing purposes of affiliates and non-affiliates. You also have the right to limit affiliates sharing over the course of everyday business purposes. Individual states may have additional sharing limitations, and companies maintain their own information sharing policies. The laws of your jurisdiction may also allow you to request corrections to your personal information and rights to file a complaint with an applicable government regulator such as a Data Protection Authority. Information Fountaindale Collects and Retention Period

Fountaindale requests personal and financial information to help assess financial objectives and goals, which Fountaindale maintains as private and confidential. Depending on the specific services we provide for you, this information can include: financial Information such as credit card numbers and bank information digital information, including e-mail, login information, and IP addresses; biographical information, like your age and sex; employment data, like salary, employment, and tax; identifying information, such as name, address, date of birth, mobile number, social security number, government identification, and marital status; We sometimes collect information from other sources. This may include:
transactional data;
account applications;
custody agreements;
brokerage agreements;
advisory agreements;
legal agreements;
investment suitability assessments;
account forms;
investment questionnaires; and
other information we need to service your account(s).


We retain your nonpublic personal information to the extent required and permitted by applicable law in furtherance of the services Fountaindale provides.

Use of your Personal Information

Fountaindale will use a Client’s personal information to do the following:
for purposes required or authorized by law, including other purposes for which you have provided your consent;
accessing to protected areas of Fountaindale’s Site;
administering our services, including for purposes of evaluation and monitoring;
providing services through Fountaindale’s related contractors, service providers, corporations, or other third parties;
assist with the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of Fountaindale and its contractors and service providers;
communicate with you and respond to your inquiries;
conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms;
protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities; and/or
perform data analyses (such as market and customer research).
Under such circumstances that we use nonpublic personal information we collect for other purposes not identified above, and where direct client consent is required under applicable rules, laws, and/or regulations, we will provide specific notice at the time we collect such personal information.


How Fountaindale Protects Information and User Risk

Fountaindale maintains electronic security measures, as well as procedural and physical measures. This includes measures to protect your information prior to, during and upon termination of our financial services engagement (i.e., disposal of your data). Our technology vendors provide security and access control over personal information and maintain policies about your data.

In general, nonpublic personal information or other information that you transmit to us online is transmitted at your own risk. Please take measures to ensure that your electronic devices and internet connections are secured.

Policy Changes

Every year, Fountaindale will send you a copy of this privacy policy for as long as you have a relationship with us. In light of developments in security or technology, or for any number of other reasons, we may review and revise this Policy; you will get a copy of material revisions and the entire policy shortly after we make them. To be clear, there will be no revisions that include sharing your non-public, personal information, other than as described in this Policy, unless we first give you an opportunity to prevent the information sharing by first notifying you.

Any Questions?

If you have any questions regarding this privacy policy or would like to exercise your rights, you may contact our Chief Compliance Officer by e-mailing info@fountaindale.co.

Definitions

Affiliates: These are companies that have common ownership or control with Fountaindale, and they can be both financial and nonfinancial companies. Nonaffiliates: These companies that do not have common ownership or control with Fountaindale; they can be financial and nonfinancial companies.