Privacy Policy

I. Introduction

Downtown Asset Mgmt PLLC and our affiliates (collectively, “Downtown Asset Mgmt,” “we,” “us,” or “our”) are committed to protecting your privacy. 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 (collectively, “using our Services”).

II. Confidentiality

We treat information you submit for the purpose of seeking investment advice with the utmost degree of confidentiality, in accordance with our professional and ethical obligations. This Policy explains our practices for our general audience but is not a waiver of fiduciary-client privilege or any other ethical duties of investment advisers. Information you provide to us in the course of seeking or obtaining investment advice is governed by our agreements and professional obligations.

III. Privacy Overview

This summary provides key details about our privacy policy. For more information, please read the full policy as set out below.

What we collect: We collect information you provide, information from your use of our Services, and information from third parties.
How we use it: We use this information to provide and improve our investment advisory services, and to send you relevant updates.
How we share it: We may share information with affiliated service providers that help us improve investment results and market our services.
Your control: We give you clear choices about controlling your personal information, including the right to opt out of certain data uses.

IV. Information We Collect

We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with you (“PII” or “PPI”). The categories of Information we may collect are as follows:

Category of Personal Information	Examples	Source
Identifiers	Real name, email address, telephone number, IP address.	You provide it directly; we collect it automatically.
Professional or Employment-Related Information	Your job title, company name, and industry.	You provide it directly.
Internet or Other Electronic Network Activity	Browsing history on our site, site search history, pages visited, time on site, interactions with our content, browser type.	We collect it automatically.
Geolocation Data	Location information (e.g., city, state) such as that inferred from your IP address.	We collect it automatically.
Inferences Drawn	Profiles reflecting a person’s interests or preferences based on their website activity.	We create it based on your activity.

V. How We Use Your Information

We use your Information for specific business purposes and only when we have a valid business reason to do so. Those reasons include:

To Provide and Improve Our Services: To operate our website, understand user interaction, and enhance functionality.
- Justification: Our legitimate interests in maintaining our digital presence; performance of a contract.
For Analytics: To monitor and analyze traffic and usage patterns to improve our content and service delivery.
- Justification: Our legitimate interests in improving our services.
For Direct Marketing: To send you newsletters, event invitations, or legal updates that may be of interest to you.
- Justification: Your consent, or our legitimate interests when a prior business relationship exists.
To Comply with Legal Obligations: To comply with applicable laws, regulations, or legal processes.
- Justification: Compliance with a legal obligation.

We may refer your request for investment advisory services to another advisor, which may provide us with money or other valuable consideration in exchange.

More generally, we may share Information with the following categories of third parties:

IT & Hosting Providers: We may share Personal Information with vendors that provide cloud hosting, security, and other technical services to operate our website and internal systems.
Analytics & Performance Providers: We may share Personal Information with partners like Google Analytics to help us understand website traffic and usage patterns.
Marketing Providers: We may share Personal Information with social media platforms and advertising networks to provide you with relevant advertising on other sites. Under several U.S. state privacy laws, this type of sharing may be defined as a “sale” or “sharing” for cross-context behavioral advertising. This activity is facilitated through the use of third-party cookies and similar tracking technologies on our website.
For Business Transfers: We may transfer Personal Information in connection with any merger, sale of assets, financing, or acquisition of our business.
For Business Reasons: We may disclose Information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

VII. Sensitive Information

We do not collect or process sensitive personal information, such as race, ethnicity, national origin, sexual orientation, or religious beliefs unless it is necessary to provide or maintain a service that you have requested.

VIII. Cookies

We use cookies and similar technologies to operate our site and enhance your experience.

Cookies: Cookies may include both necessary cookies and non-essential cookies, such as analytics, functional, and advertising cookies.

IX. Your Privacy Rights

Depending on where you reside, you may have certain rights regarding your Personal Information.

In certain states, you have the right to direct us not to “sell” or “share” your Personal Information, or process it for purposes of targeted advertising and/or certain types of automated profiling. You can exercise your right to opt out in two ways:

Manually: By emailing us and informing that you want to opt out, we agree to refrain from keeping, using, or sharing your information.

B. Additional Privacy Rights

Depending on your jurisdiction, you may also have rights to privacy that include:

The Right to Know and Access: To ask what Personal Information we have collected and how we have used and shared it.
The Right to Deletion: To request that we delete your Personal Information, subject to certain exceptions.
The Right to Correction: To request that we correct inaccurate Personal Information.
The Right to Data Portability: To request a copy of your information in a usable format.
The Right to Know Third-Party Recipients: To request the categories of third parties to which we have disclosed your Personal Information.
The Right to Revoke Consent: When we rely on your consent for processing, you may revoke that consent at any time, such as by unsubscribing from our marketing emails.
The Right to Non-Discrimination: To be free from discrimination for exercising your privacy rights.

To exercise any of these additional rights, please email us. We will need to verify your identity before processing your request. This will involve providing personal information to match against the information we have on file for you, potentially including your name, email address, and phone number. If you would like to designate a privacy agent, you must provide them with written permission, and we may require you to verify your own identity directly with us. If we deny your request, you may have a right to appeal our decision, depending on your state’s law.

X. Data Retention

We retain your Information for as long as is necessary to fulfill the purposes for which it was collected, and to comply with our legal and professional obligations, considering factors like the duration of our relationship, the purposes for which the data was collected, applicable statutes of limitations, and professional conduct rules.

XI. Children’s Privacy

Our services are not directed to people under the age of 18. We do not knowingly sell the personal data of consumers under 18 or use their data for targeted advertising. If you believe we have inadvertently collected such information, please contact us to request its deletion.

XII. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the “Last Updated” date.

XIII. Contact Us

If you have questions about this Privacy Policy, you can use our contact page to reach us.