Privacy Policy

Effective date: 05/15/2024
Amber Equity LLC (“Amber Equity,” “we,” “us,” or “our”)
Address: 3960 Howard Hughes Pkwy, Las Vegas, NV, USA
Contact: info@amberequity.com

This Privacy Policy explains how we collect, use, share, and protect information in connection with our website, emails, scheduling tools, and the services we provide, including:

• Smart Pilot (rules-based currency strategy) offered either as a managed account (PAAM) through registered partners or as a license to qualified operators,

• Project OPM (a funding concierge that helps small businesses match with suitable lenders),

• Partnership and JV programs (e.g., RIAs/CPAs, media/newsletters, distribution assets),

• General inquiries, meetings, and marketing.

This notice is for information only and does not constitute legal, tax, or investment advice.

1) Information we collect

We collect information in three ways: (a) directly from you, (b) automatically from your device, and (c) from third parties you authorize.

A. Information you provide

• Contact & identity data: name, email, phone, company, job title, country/state, time zone.

• Meeting & form data: topics of interest, suitability/discovery answers you choose to share, notes you or we add.

• Business/financial context: if you explore Smart Pilot or Project OPM, you may provide non-public information relevant to suitability, risk tolerance, account setup, or financing needs (e.g., business revenue range, entity type).

• Application data for Project OPM: only if you ask us to connect you with lenders; you control what we send.

B. Information collected automatically

• Usage & device data: IP address, browser, pages viewed, referral source/UTM, timestamps, approximate location, and cookie identifiers.

• Scheduling & email events: when you open our emails or book/cancel meetings.

C. Information from third parties (with your authorization)

• Referral partners / registered firms: status updates such as meeting attended, account opened/funded, non-personal AUM totals for attribution, and compliance confirmations.

• Lenders (Project OPM): application status and funding decisions when you choose to proceed.

We do not require or want biometric data, government ID images, or full bank credentials on our website. KYC/AML for managed accounts is handled by the registered CTA/RFED/FCM/RIA or broker you choose; those firms’ privacy policies govern their processes.

2) How we use information

We use information to:

• Provide and improve services: respond to inquiries, schedule calls, evaluate fit/suitability, deliver demos or educational materials, and operate our programs.

• Partner/JV programs: attribute meetings and funded accounts to partners, calculate referral/revenue shares, and run pilots.

• Project OPM: at your direction, share your application data with selected partner lenders and communicate status updates back to you.

• Compliance & risk: maintain records, manage conflicts, detect abuse, satisfy legal/contractual obligations.

• Marketing (opt-out anytime): send updates, invites, or educational content; measure campaign performance; build audience segments.

• Analytics & site operations: understand usage, improve UX, debug, and secure the site.

Legal bases (GDPR/UK): performance of a contract, legitimate interests (e.g., running our business, securing services, B2B marketing), consent (where required), and legal obligations.

3) How we share information

We share information only as needed and with safeguards:

• Service providers / processors: website hosting, email and calendar tools, scheduling (e.g., Calendly), CRM/analytics (e.g., Google Analytics/Tag Manager, Airtable/HubSpot), e-signature and storage providers.

• Registered financial partners: when you pursue a managed-account option, we coordinate with registered CTAs/RIAs and/or brokers (RFED/FCM). Client agreements and KYC are with those firms.

• Lending partners (Project OPM): only if you choose to be matched, we share the application data you authorize with selected lenders; they make underwriting decisions and provide funding.

• Affiliates / portfolio companies: to help operate and integrate our offerings.

• Business transfers: in a merger, acquisition, asset sale, or similar transaction.

• Legal & safety: to comply with law, enforce terms, or protect rights, safety, and security.

We do not sell your personal information for money. We may be considered to “share” data for cross-context behavioral advertising (e.g., analytics or retargeting) under some state laws; see Your Privacy Choices below.

4) Cookies, analytics, and tracking

We use cookies and similar technologies to operate the site, remember preferences, measure performance, and attribute traffic (e.g., UTM parameters). You can:

• Adjust browser settings to block or delete cookies,

• Use our cookie banner preferences (if present), and

• Opt out of Google Analytics advertising features via Google’s tools.

We do not respond to browser “Do Not Track” signals.

5) Data retention

We keep information only as long as needed for the purposes described, including:

• Business records and compliance: generally 3–7 years (or as required by law/contract),

• Marketing: until you unsubscribe or your information becomes inactive for a reasonable period,

• Partner attribution and audit logs: as needed to honor contractual obligations and resolve disputes.

6) Security

We use administrative, technical, and physical safeguards designed to protect information (encryption in transit, access controls, logging, least-privilege). No method of transmission or storage is 100% secure; please use caution when sharing information online.

7) International data transfers

We may process and store information in the United States and other countries. Where required, we rely on appropriate safeguards (e.g., Standard Contractual Clauses) for transfers from the EEA/UK/Switzerland.

8) Your rights & choices

A. Email/marketing

• Click Unsubscribe in any email or write to info@amberequity.com.

B. GDPR/UK (if you are in the EEA/UK)

You may request to access, correct, update, delete, restrict, or object to processing; and request data portability. Where processing is based on consent, you can withdraw it at any time. We may need to verify your identity and may decline requests where an exception applies.

C. California (CCPA/CPRA)

California residents can request to know, access, correct, or delete personal information, and to opt-out of “sale” or “sharing” for cross-context behavioral advertising. We do not use or disclose sensitive personal information for purposes other than those allowed by CPRA.
To exercise rights, email info@amberequity.com with “CCPA Request” and describe your request. We will verify identity before acting. You may also use a legally authorized agent.

9) Children’s privacy

Our services are not intended for individuals under 18. We do not knowingly collect personal data from children. If you believe a child provided information, contact us and we will delete it.

10) Third-party sites

Our site may link to third-party websites or platforms (e.g., brokers, lenders, calendars). Their privacy policies govern those properties; we are not responsible for their practices.

11) Program-specific notes

Smart Pilot — Managed Account (PAAM)

• Offered in the U.S. through registered partners (e.g., CTA/RIAs and approved brokers). Those entities handle client onboarding, agreements, KYC/AML, and trading permissions. We may receive limited status and attribution data (e.g., account opened/funded date, non-personal AUM totals) to operate programs and pay partners.

Smart Pilot — License

• If you license our rules/software, we process your account and billing details, and provide support communications. Trading activity and infrastructure are your responsibility.

Project OPM — Funding Concierge

• We are not a lender. At your request, we share your application data with one or more partner lenders. We receive updates about application status and funding decisions. Lenders’ privacy policies govern their processing.

Partnerships & JVs (RIAs/CPAs/media/creators)

• We maintain attribution and reporting to calculate agreed revenue shares (e.g., consults booked, funded accounts, fee amounts). Where required, solicitors work under a registered firm’s compliance program.

12) Your privacy choices (links)

• Unsubscribe from emails: link in any email.

• Cookie/Tracking preferences: use the banner (if shown) or your browser settings.

• Do Not Sell or Share My Personal Information: [provide a link or email info@amberequity.com with the subject “Do Not Sell/Share”].

• Data requests: email info@amberequity.com with the subject “Privacy Request.”

13) Changes to this Policy

We may update this Privacy Policy from time to time. The “Effective date” above shows when it was last revised. Significant changes will be posted on this page. Your continued use of our site/services after changes means you accept the updated Policy.

14) Contact us

Questions or requests about this Policy or your information:
info@amberequity.com
Amber Equity LLC, 3960 Howard Hughes Pkwy, Las Vegas, NV, USA

Important notes (keep below the fold)

• This template is intended to be clear and practical, but it is not legal advice.

• If/when you operate as or under a registered CTA/RIA, ensure your site links to and is consistent with the partner firm’s privacy notice and solicitor disclosures.

• If California users visit your site, add a footer link labeled “Do Not Sell or Share My Personal Information.”

• If you deploy a cookie banner, wire it to actually set preferences (or keep analytics to strictly necessary).