GLBA Privacy Policy
This notice is effective as of: September 30, 2022
WHAT DOES LIONHEART STRATEGIC MANAGEMENT LLC (“LIONHEART”) DO WITH YOUR PERSONAL INFORMATION?
FACT 1: WHY?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
NOTE: If you reside in the European Economic Area (“EEA”), United Kingdom, or Switzerland, then you also are subject to our GDPR Privacy Notice. For those residents, in the event of a conflict between this Privacy Notice and that GDPR Privacy Notice, the GDPR Privacy Notice shall control.
FACT 2: WHAT?
This GLBA Privacy Notice covers information you provide to us for purposes of investing in our investment funds, vehicles, and accounts, utilizing our investment advisory or management services, or registering with our investor portal. The types of personal information we collect and share can include:
Contact Details (e.g., name, physical address, email address, and phone number)
Financial Information (e.g., debit card and bank account information)
Identity Verification (e.g., SSN, passport information)
Information you provide to any of our partners for purposes of the financial transactions and services they provide to you fall under their privacy notices and, if shared with us, are subject to the terms of those notices.
FACT 3: HOW?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Lionheart chooses to share; and whether you can limit this sharing.
| REASONS WE CAN SHARE YOUR PERSONAL INFORMATION | DOES LIONHEART SHARE? | CAN YOU LIMIT THIS SHARING? |
| For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
| For our marketing purposes – to offer our products and services to you | Yes | No |
| For joint marketing and other financial companies | Yes | No |
| For our affiliates’ everyday business purposes – information about your transactions and experiences | Yes | No |
| For our affiliates’ everyday business purposes – information about your creditworthiness | No | We don’t share |
| For our affiliates to market to you | Yes | Yes |
| For non-affiliates to market to you | No | We don’t share |
TO LIMIT OUR SHARING
You may email us at privacy@lionheartstrategic.com with your request to limit our sharing of information.
Please note: If you are a new customer, we can begin sharing your information thirty (30) days from the date we sent this notice. When you are no longer our customer, we may continue to share your information as described in this notice.
However, you can contact us at any time to limit our sharing.
QUESTIONS?
If you have any questions, please email us at privacy@lionheartstrategic.com.
Who we are:
Who is providing this notice?
Lionheart Strategic Management LLC
What we do:
How does Lionheart protect my personal information?
We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information that we receive against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use.
How does Lionheart collect my personal information?
We collect your personal information, for example, when you:
Invest in one of our investment funds, vehicles and accounts or use our investment advisory or management services
Create and access an investment account through our online portal
Information provided for the use of our partners falls under their privacy notices; the information shared between our partners and us is to perform the transactions you have requested unless we are permitted to share the information with our partners for marketing purposes (subject to any opt-in or opt-out rights set out in those notices). We also collect your personal information from others, such as credit bureaus, affiliates or other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only:
Sharing for affiliates’ everyday business purposes—information about your creditworthiness
Affiliates from using your information to market to you
Sharing for non-affiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
Definitions
Affiliates
Companies related by common ownership or control. They can be financial and non-financial companies.
Our affiliates include companies with a Lionheart and Fisher Brothers name.
Non-affiliates
Companies not related by common ownership or control. They can be financial and non-financial companies.
Non-affiliates with whom we may share can include (i) other financial services companies (including other financial institutions, such as banks) that provide services made available through our Lionheart Services; and (ii) non-financial service providers such as hosting platforms, KYC/AML and fraud protection vendors, sanctions screening vendors, data processors, marketing partners, and API integrators.
Joint marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
OTHER IMPORTANT INFORMATION
We will comply with applicable state privacy laws:
California, North Dakota and Vermont Residents: We will not share your information with companies outside of Lionheart and our affiliates, except for our everyday business purposes, for marketing our products and services to you, or with your consent. We will not disclose credit information about you within or outside Lionheart except as required or permitted by law.
Additional Information collected. The only other personal information we receive is analytics information relating to internet or network activity and geolocation.
Business transfers. In the event of a merger, dissolution, reorganization, or similar corporate event, or the sale of all or substantially all of our assets (including, in each case, any due diligence relating thereto), we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this GLBA Privacy Notice.
Access, Deletion and Updating Personal Information. If you have any questions about viewing or updating information we have on file about you, or wish to request that we delete your information, please contact us at [email address]. We will comply with such requests to the extent required by applicable law and expressly reserve the right to retain any data that we are permitted or required to keep.
Data Stored in the United States: Irrespective of where you are located, we store all of your Personal Information in the United States. You understand that by providing us your Personal Information you are transmitting it to us in the United States.
Do Not Track: Our websites and apps are not designed to respond to "do not track" requests from browsers.
“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.
Third-Party Links: We may provide links to other sites or resources provided by third parties. These links are provided for your convenience only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third-party links on our sites, you do so entirely at your own risk and subject to the terms and conditions of those sites.
Children: We do not knowingly collect personal information from children under the age of 13 through our sites. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Notice by instructing their children never to provide us personal information. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will endeavor to delete that personal information from our databases.
Hello, World!