Privacy Policy | CleverAlpha Dark

Protecting your private information is our priority. This Statement of Privacy applies to CleverAlpha Asset Management, LLC and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to CleverAlpha Asset Management include CleverAlpha. The CleverAlpha website is a Digital Asset Management site. As an SEC-registered RIA, our privacy practices align with ADV Part 2A. We collect SSN for tax reporting, identification and KYC requirements as well as for sharing limited to custodians. By using the CleverAlpha website, you consent to the data practices described in this statement. Please read this notice carefully to understand what we do.

Collection of your Personal Information

In order to provide you with products and services offered on our Site, CleverAlpha will need to collect personally identifiable information when you:

Elect to open up an account,
Tell us about your investment or retirement goals,
Submit your bank account, credit card or other payment information when funding your account,
Make deposits or withdrawals from your account,
Send us an email message, or
If we gather additional personal or non-personal information in the future or receive information about you from information services and consumer reporting agencies.

Other types of personal information we collect can include:

Social Security Number
Investment experience
Income
Account transactions
Assets
Retirement assets
Collection of your Personal Information such as your age and gender

CleverAlpha may also collect anonymous demographic information, which is not unique to you.

Information about your computer hardware and software may be automatically collected by CleverAlpha. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the CleverAlpha website.

State laws and individual companies may give you additional rights to limit sharing; however, all financial companies need to share customers’ personal information to run their everyday business. In the section below, we list reasons financial companies can share their customers’ personal information; the reasons CleverAlpha chooses to share; and whether you can limit this sharing.

Use of your Personal Information

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. Specifically, CleverAlpha collects and uses your personal information to operate its website(s) and deliver the services you have requested. CleverAlpha may also use your personally identifiable information to inform you of other products or services available from CleverAlpha.

Reasons we can share your Personal Information

CleverAlpha may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on CleverAlpha or the site; (b) protect and defend the rights or property of CleverAlpha; and/or (c) act under exigent circumstances to protect the personal safety of users of CleverAlpha, or the public.

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.

For our marketing purposes, CleverAlpha does not share information with our affiliates or other non-affiliated third parties to offer you products and services without your consent.

CleverAlpha does not sell, rent or lease its customer lists to third parties

For joint marketing with other financial companies. Federal and certain state laws give us the right to share your information with banks, registered Investment advisors, retirement plans and other financial institution programs with which you are a customer and where a formal agreement exists between us and them to provide or market financial products or services to you. However, we will not share your information with these financial companies for marketing purposes if your financial advisor is not affiliated with them without your consent, but we may share information with these financial companies where necessary to service your accounts.

Security of your Personal Information

CleverAlpha secures your personal information from unauthorized access, use, or disclosure. CleverAlpha uses the following methods for this purpose:

– SSL Protocol

When personal information (such as a bank account number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

CleverAlpha employs state-of-the-art security measures to protect your data, including:

Encryption: Data in transit is protected using TLS 1.3 (or higher), while data at rest is secured with AES-256 encryption.
Multi-Factor Authentication (MFA): We require MFA for accessing sensitive account information.

Tracking User Behavior

CleverAlpha may keep track of the websites and pages our users visit within CleverAlpha, in order to determine what CleverAlpha services are the most popular. This data is used to deliver customized content and advertising within CleverAlpha to customers whose behavior indicates that they are interested in a particular subject area.

Use of Cookies

The CleverAlpha website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize CleverAlpha pages, or register with CleverAlpha site or services, a cookie helps CleverAlpha to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same CleverAlpha website, the information you previously provided can be retrieved, so you can easily use the CleverAlpha features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the CleverAlpha services or websites you visit.

Links

This website may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

E-mail Communications

From time to time, CleverAlpha may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from CleverAlpha or click on a link therein.

Automated Decision Making and Artificial Intelligence

Our robo-advisory services utilize AI algorithms to analyze market data and deliver tailored investment recommendations. In accordance with FINRA standards:

We ensure transparency regarding the role of automated systems in our advisory process and will let users know what information has been influenced or generated by AI models.

Changes to this Statement

CleverAlpha reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our site, and/or by updating any privacy information on this page. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

OTHER IMPORTANT INFORMATION

If you close your account and transfer your account to another firm, in the process of transferring your investments, we may share your information with the new broker-dealer or custodian that you or your representative selects. If our representative servicing your account leaves us, the representative may be permitted to retain copies of your nonpublic personal information so that he/she can assist with the transfer of your account and continue to serve you at a new firm. When your representative associates with a new firm, the representative’s continuing use of such information becomes subject to the new firm’s privacy policy.

If your address is in Vermont or California, CleverAlpha will automatically limit information sharing with non-affiliates for marketing purposes. The following notice is required to be made under Nevada law to Nevada customers. At any time, you may request in writing to be placed on our internal “Do Not Call” list.

Contact Information

CleverAlpha welcomes your questions or comments regarding this Statement of Privacy. If you believe that CleverAlpha has not adhered to this Statement, please contact us at:

CleverAlpha Asset Management, LLC
425 15th Street
C3321
Manhattan Beach, California 90266

Email Address: support@cleveralpha.com
Telephone number: 310-293-7837

Effective as of March 25, 2025