Privacy Policy

1. Introduction

Spry & Hodler Investment Group ("Company," "we," "us," or "our") is committed to protecting the privacy of our clients, prospective clients, and website visitors. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you visit our website, use our investment platform, or engage with our services.

By accessing our services, you consent to the data practices described in this policy. If you do not agree with the terms of this privacy policy, please do not access our platform.

2. Information We Collect

Personal Information

We may collect the following categories of personal information when you register for an account, make an investment, or interact with our platform:

• Identity Data: Full legal name, date of birth, government-issued identification numbers, nationality, and photograph.
• Contact Data: Email address, telephone number, mailing address, and residential address.
• Financial Data: Bank account details, investment history, income information, net worth statements, source of funds documentation, and tax identification numbers.
• Technical Data: IP address, browser type and version, device identifiers, time zone setting, operating system, and platform usage data.
• Transaction Data: Details of investments, withdrawals, transfers, and other transactions conducted through our platform.

Automatically Collected Information

When you access our website, we automatically collect certain information including your IP address, browser type, referring/exit pages, operating system, date/time stamps, and clickstream data. We use cookies and similar tracking technologies to collect this information.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To create, maintain, and secure your investment account
• To process transactions and send related notifications
• To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulatory requirements
• To provide customer support and respond to inquiries
• To send administrative information, such as changes to our terms and policies
• To personalize your investment experience and provide tailored recommendations
• To monitor and analyze usage trends to improve our platform
• To detect, prevent, and address fraud, security breaches, and technical issues
• To comply with applicable laws, regulations, and legal processes

4. Information Sharing and Disclosure

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

• Service Providers: With third-party vendors who perform services on our behalf, such as payment processing, data analysis, identity verification, and customer service.
• Regulatory Authorities: With financial regulators, tax authorities, and law enforcement agencies as required by applicable law or in response to valid legal processes.
• Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as a business asset.
• With Your Consent: We may share your information with third parties when you have given explicit consent to do so.

5. Data Security

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

• 256-bit SSL/TLS encryption for all data transmissions
• AES-256 encryption for data at rest
• Multi-factor authentication (MFA) for account access
• Regular security audits and penetration testing
• Strict access controls and employee training programs
• SOC 2 Type II certified infrastructure

While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure.

6. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. Financial records are retained for a minimum of seven (7) years in accordance with regulatory requirements.

7. Your Rights

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

• Access: The right to request a copy of the personal data we hold about you.
• Rectification: The right to request correction of inaccurate or incomplete personal data.
• Erasure: The right to request deletion of your personal data, subject to legal retention requirements.
• Restriction: The right to request that we restrict the processing of your personal data.
• Portability: The right to receive your personal data in a structured, commonly used format.
• Objection: The right to object to certain types of processing, including direct marketing.

To exercise any of these rights, please contact our Data Protection Officer at privacy@spryandhodler.com.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience, analyze trends, administer the website, and gather demographic information. You can control cookies through your browser settings, though disabling cookies may limit functionality of certain features.

9. International Data Transfers

Your information may be transferred to and maintained on servers located outside of your jurisdiction. We ensure appropriate safeguards are in place, including Standard Contractual Clauses and adequacy decisions, to protect your data during international transfers.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on this page and updating the "Last Updated" date. Continued use of our services after changes constitutes acceptance of the updated policy.

11. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us: