Online Privacy Notice

The website (“Website”) for CapAcuity, LLC (the “Company,” “we,” or “us”), was created to provide information about our Company, including our Consulting, Investment Advisory, and Asset Management services, (together with the Website, the “Services”).  We value the privacy of our visitors (“you,” “your,” or “user”), and in order to protect your personal information, we have implemented the following Privacy Policy with provisions that apply to the collection of data by the Company, its subsidiaries, and its affiliates.

The Company’s website is located at By using this website, you agree to abide by the Terms and Conditions that may from time to time be posted on the website. If you do not agree to these terms and conditions, you should not access or use the Website.

Our Privacy Policy discloses the type and nature of information we collect and how we use it, as well as the choices you can make about the way your information is collected and used.  We also explain how any requests for personal or personally identifiable information will be used.  If you follow any links that direct you away from the Website, this privacy policy will not apply to your activity on the other websites you visit.  We do not control the privacy policies or the privacy practices of any third parties.

We may from time to time make available mobile applications (“Apps”) to allow you to access your account using wireless and mobile devices. This Privacy Policy applies to any nonpublic personal or other information that we may collect through Apps.

Information We Collect

The Company may collect personal information from you when you visit the Website. While some items are optional, most are required for legal or security purposes. You may choose to provide additional information during subsequent visits to the Website. The type of information we collect includes, but is not limited to, personal data required to verify your identity, and aggregated personal data pertaining to your Website visits that help us maintain the appropriate features, functionality and user experience.

No Anonymous Postings

The Website hosts require that users post information under their actual given name.  We ask that our participating users identify themselves in this manner, and if you object, we request that you refrain from using the Website.  We urge you to review your information regularly to ensure that it is correct and complete.  If you believe that any of your information is incorrect, or if you have any questions regarding this Privacy Policy, please contact us immediately.

Personal Data

You may be required to provide basic personal data. Personal data means information that can be associated with you and can be used to identify you. Personal data does not include information that does not identify a specific person. You agree to the practices regarding your personal data described in this Privacy Policy when you use the Website. The Company may use this data to: (i) enable you to log in to the Website; (ii) establish your ability to view certain materials through the Website; (iii) guard against potential fraud; (iv) contact you if there is a problem with your account; and (vi) maintain regular communications with you as may be necessary to inform you of enhancements and other Company updates. The Company will also gather the names and email addresses of users who contact us through the Website with questions about our Company. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested to do so.

In addition, we may collect information such as your Internet Protocol (IP) address and/or domain, the type and version of your Internet browser software and operating system you use, the date, time, and duration of your online access, the specific pages, buttons, images, links, and forms that you access while visiting the Website, the type of device you use to access the Website (such as a personal computer, iPhone, or iPad), your mobile carrier and/or your Internet Service Provider. Collection of this data alone does not personally identify you.

Keeping your information accurate and up to date is very important. If your personal or account information is incomplete, inaccurate or not current, you agree to contact us immediately.


Regardless of whether you register for an account or submit an application, the Company may send one or more “cookies” to your computer. Cookies are small text files placed on your web browser when you visit our Website that store information on your computer, such as your Website preferences. We use cookies when you sign in to keep track of your personal session, including some account identifiers to ensure that you are the only person making changes to your account. We also use cookies to track your activity on the Website as a unique person.  For security purposes, all of this information is stored in encrypted form.  No personal information about you is stored.   You can set your web browser to inform you when cookies are set, or to prevent cookies from being set altogether.  Please note that if you decline to use cookies, you may experience reduced functionality and slower Website response times. In some instances, declining to use our authentication-related cookies may prevent you from using the Website entirely.

The Company (or our service providers, such as Google Analytics) may also collect web surfing data related to your use of the Website.  Such information may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), and operating system. We may also track which of our Website pages you access and how frequently, referral or exit pages, clickstream data, and the dates and times that you visit the Website. This data may be collected using cookies, web beacons, pixels, Flash objects, page tags or similar tools. You are free to decline such technologies if your browser permits. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals. Web surfing data and similar information may be aggregated for administrative purposes. The Company may, for example, use this aggregated information in the administration of the Website to improve its usability and to evaluate particular advertising campaigns, search engine optimization strategies, and other marketing activities. We also use it to help optimize the Website based on the needs of our users.

Safeguarding User Information

The security of your information is very important to us, and we take commercially reasonable steps to safeguard such information. These steps and procedural safeguards are in line with industry standards. Practices include encryption and authentication tools to maintain the confidentiality of user information including secure socket layer technology (SSL); limits on, to the extent possible, who or what can access your user information; and the use of cookies to help anonymously recognize you as a repeat visitor and to track Website traffic patterns. Nevertheless, we can never ensure or guarantee the security of your user information, nor do we make any representation or warranty regarding the security of your account. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Website and the Services in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

You may also find additional information on our products and services through our social media sites such as Facebook, LinkedIn, or Twitter. Please keep in mind that any information you share is visible to all participants on these social media sites and you should never post any sensitive personal information (such as account number or tax identification). Please carefully review the Terms of Use and Privacy Policy on these social media sites as they may be different than our own policies.

Children Online Privacy Protection Act and CAN-SPAM Act

We respect the privacy of children and encourage all parents to supervise their children’s computer usage. We do not market to children and the Website is not intended to be used by anyone under 18 years old. The Federal Trade Commission enforces the Children Online Privacy Protection Act (COPPA) which details what operators of websites and online services must do to protect children’s privacy and safety online.  For more information on COPPA, please visit the Federal Trade Commission website at We also abide by the CAN-SPAM act which sets rules for commercial email, establishes requirements for commercial messages, gives recipients the right to stop receiving emails, and has tough penalties for violations.

Security Policy

We limit access to the personal information we have about you to those employees and other persons who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. The Website is built upon a secure infrastructure with multiple layers of protection, and we use industry-standard encryption technologies to safeguard your information. Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Website. Generally, identification and authentication take place through the use of your username and a password and/or while logging in with one of our support staff.

However, the internet is not a fully secure environment, and we cannot ensure or warranty the security of any information transmitted to or generated by us in connection with the Website. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, technical, and physical, or other operational, safeguards. You play a critical role in protecting your information by maintaining up-to-date computer security protections. Steps you take to ensure the security of your computer, computer passwords, or other personal identifier authentication mechanisms are key components of the protection of your personal information.

Sharing Your Information

The Company does not sell or rent personal information about its users for marketing purposes. We may work with a number of trusted partners who perform vital functions as part of our operations. The Company also works with providers of hosting services for the Website, electronic signature providers, and electronic payment service providers.

We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business. Examples of third parties might include those that perform data processing, data storage, payment services, technology support and services, customer service, risk solution provision, analytics, fraud prevention, reporting, tax documentation, and custody or escrow services. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services. Our partners are legally required to keep your information private and secure. We may also share some of your personal information as otherwise permitted or required by law or as authorized by you.

We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process.  We further reserve the right to disclose any of your personal information that we believe is appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Website or our Services, or to protect the rights, property or personal safety of the Company, its users, agents, or others. The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive.

Electronic Communications

The Company may send you email notifications from time to time.  Some notifications may be required elements of your transactions on our platform, such as confirmations of particular actions you have taken. These notices are sent typically to notify you of a change in status. We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection. In other cases, these notifications could address changes to various legal agreements or Website policies. Generally, you may not opt out of such service-related emails.

We may also send you responses to emails you send us, if appropriate.  From time to time, we may also send user surveys, requests for user feedback regarding user experience and Website operations, or marketing offers from us or on behalf of our marketing partners.  Completing these surveys, answering requests for feedback, or accepting any offer is strictly voluntary.  If you do not wish to receive these surveys, user feedback emails, and/or marketing offers, please opt out of any offer email you receive from us.

International Users

The Website may be accessed by users located outside the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States, and that by providing your personal information on or through the Website then you consent to that transfer.

Security Systems Breach

If we learn of a security systems breach, we will attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Website in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

Precautionary Measures

You can take several precautions to protect the security of your computer and personal information. For instance, you can use a well-chosen password and restrict access to your email account. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on the Website, be sure that you log out and close the browser window. You should also be aware of fraudulent attempts to gain access to your account information through “phishing,” whereby scammers try to bring unsuspecting people to a website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on this fake site, scammers will ask for login information to gain access to people’s accounts and withdraw their money. The Company will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go the website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain.

Changes to Privacy Policy

This Privacy Policy is subject to change periodically without notice. You agree to review it periodically. If we make changes to the Privacy Policy, we will revise the “Last Updated” date on this Policy. Any changes to this Privacy Policy will become effective when we post them. This Privacy Policy attempts to comply with federal and state regulations regarding privacy. Clients may have additional rights under other foreign or domestic laws that may apply to them. Your use of the Website following any changes means that you accept the revised Privacy Policy and are otherwise responsible for compliance with applicable laws and regulations.