Every Privacy Policy

Introduction

Every Securities LLC ("Every Securities," "we," "us," or "our"), a registered investment advisor, considers the protection of your information to be a most important priority. This Privacy Policy explains how we collect, use, share, and protect your personal information when you visit our website, use our application, or engage with any of our services (collectively, the "Services").

Our privacy policy and practices are designed to support this objective. We want you to understand what information we collect and how we use it. We would be unable to provide our Services to you without the personal data you provide us, which is why we take our responsibility to protect your personal data very seriously.

If you do not want us to collect personal data from you or share personal data with any third parties or otherwise disclose your personal data, you should not access our website, download or use our application, or use our Services.

1. Personal Data We Collect

We may collect non-public, sometimes personal, information about our clients and parties who engage our firm to participate in certain securities transactions from the following sources:

• Information we receive from you on applications and other forms
• Information we receive from you in order to provide certain investment banking advisory services
• Information concerning your transactions with us, our affiliated persons, or others
• Information from a consumer-reporting agency or vendor providing anti-money laundering or Know Your Customer compliance services

This information generally falls into the following categories:

Identifiers

• Examples: First and last name, email address, mailing address, username, password, account credentials, device fingerprint
• Sources: Directly from you (forms you complete, services you obtain from us)
• Purposes: 
  
  • Managing your account information
  • Helping you access and restore access to your account
  • Preventing unauthorized access
  • Sending administrative information
  • Providing our investment advisory services

Customer Records

• Examples: Bank account details, bank routing and account numbers, social security numbers, government-issued identification, credit information, investment objectives and history
• Sources: Directly from you
• Purposes: 
  
  • Verifying your identity to comply with anti-money laundering laws
  • Processing transactions
  • Complying with applicable securities regulations and consumer protection laws
  • Providing our investment advisory services

Internet Activity Information

• Examples: IP address, device ID number, browsing history, interaction with our website/application
• Sources: Indirectly from your activity on our platforms
• Purposes: 
  
  • Analytics and performance monitoring
  • Security monitoring
  • Service improvement

2. How We Use Your Personal Data

We use your personal data for the following purposes:

• Providing Our Services: To deliver the services you've requested, process transactions, and maintain your account
• Communication: To respond to your inquiries, provide customer support, and send important notices
• Security: To verify your identity, protect against fraudulent or unauthorized activity
• Improvement: To analyze usage patterns, troubleshoot issues, and enhance our Services
• Marketing: To inform you about products, services, or promotions that may interest you (subject to your preferences)
• Legal Compliance: To fulfill our legal obligations and respond to legitimate requests from authorities

3. Information Sharing Practices

We do not disclose any non-public information about you to anyone, except as permitted or required by law.

We restrict access to non-public personal information about you to those employees, affiliated persons and registered representatives who need to have access to such information in order to provide securities related services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information.

In limited circumstances permitted by law, we may share your personal data with:

Service Providers

• Third-party vendors, consultants, contractors, and other service providers who help us provide the Services and who need access to such information to do their work
• Examples include identity verification services, cloud hosting providers, and customer support tools
• All sharing is conducted under appropriate data protection agreements

Business Transfers

• If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of company assets, your personal data may be transferred as part of that transaction
• The acquiring company would continue to be bound by this Privacy Policy until it is changed

Legal Requirements

• To comply with applicable laws and regulatory requirements (including SEC and FINRA regulations)
• To respond to subpoenas, court orders, or legal process
• To protect our rights, privacy, safety, or property
• To detect, prevent, or address fraud, security or technical issues

4. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Authenticate users and maintain your login sessions
• Remember your preferences and settings
• Understand how you navigate through our website
• Analyze the performance of our website and services
• Deliver relevant advertising
• Prevent fraud and enhance security

You can manage cookie preferences through your browser settings, though blocking certain cookies may impact your experience and the functionality of our Services.

5. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal data:

For California Residents (CCPA Rights)

• Right to Know: Request what personal information we've collected, used, disclosed, or sold
• Right to Delete: Request deletion of personal information we've collected
• Right to Opt-Out: Opt-out of the sale of your personal information (note: we do not currently sell personal information)
• Right to Non-Discrimination: Receive equal service and pricing even if you exercise your privacy rights

For All Users

• Access: Request access to your personal data
• Correction: Request correction of inaccurate data
• Restriction: Request restriction of processing in certain circumstances
• Objection: Object to processing of your personal data
• Data Portability: Request transfer of your data to you or a third party

To exercise any of these rights, please contact us at [your privacy email]. We may need to verify your identity before responding to your request.

6. How We Protect Your Data

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of sensitive information
• Secure access controls
• Regular security assessments
• Employee training on data protection
• Contractual safeguards with third-party processors

However, no method of transmission over the Internet or electronic storage is 100% secure, so we cannot guarantee absolute security.

7. Data Retention

We retain personal data only for as long as necessary to:

• Fulfill the purposes outlined in this Privacy Policy
• Comply with legal obligations
• Resolve disputes
• Enforce our agreements

When personal data is no longer needed, we will securely delete or anonymize it.

8. Third-Party Links

Our website and application may contain links to third-party websites or services that are not owned or controlled by us. This Privacy Policy only applies to our Services. We have no control over and assume no responsibility for the privacy practices of any third-party sites or services.

9. Children's Privacy

Our Services are not directed to individuals under 16 years of age. We do not knowingly collect personal information from children. If we learn we have collected personal information from a child under 16, we will delete that information as quickly as possible. If you believe a child under 16 has provided us with personal information, please contact us.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The revised Privacy Policy will be effective as of the updated date at the top of this page. We encourage you to review this Privacy Policy periodically.

11. Contact Us

If you have any questions regarding this policy or our data practices, please contact us:

Every Securities LLC Phone: (650) 719-1492 Email: support@Everysecurities.io

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