Privacy Policy

We collect several types of information in connection with the services we provide:

Personal Identification Information: Name, address, email address, telephone number, date of birth, Social Security Number or Tax Identification Number, government-issued identification numbers, and other information that identifies you as an individual.

Financial Information: Account numbers, investment objectives, risk tolerance, net worth, income, investment experience, tax information, and transaction history.

Technical Information: IP address, browser type, operating system, referring URLs, pages visited, time spent on pages, and other usage data collected through cookies and similar tracking technologies.

Communications: Records of correspondence, emails, phone calls, and meeting notes related to your account or inquiries.

We collect this information directly from you when you open an account, complete forms, correspond with us, or use our website. We may also collect information from third parties such as credit reporting agencies, identity verification services, and publicly available sources.

We use the information we collect for the following purposes:

Service Delivery: To open and maintain your investment account, execute transactions, provide investment advisory services, and fulfill our contractual obligations to you.

Regulatory Compliance: To comply with applicable laws and regulations, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, tax reporting requirements, and SEC regulations.

Communication: To send account statements, trade confirmations, regulatory notices, and other communications required or permitted by law or your account agreement.

Risk Management: To assess and manage investment risk, conduct due diligence, and protect against fraud and unauthorized transactions.

Service Improvement: To analyze usage patterns, improve our website and services, and develop new investment products and services.

Marketing: With your consent, to send you information about our services, market commentary, and investment insights. You may opt out of marketing communications at any time.

We do not sell your personal information to third parties. We may share your information in the following circumstances:

Service Providers: We share information with third-party service providers who assist us in operating our business, such as custodians, broker-dealers, technology providers, and compliance consultants. These parties are contractually obligated to protect your information and use it only for the purposes for which it was disclosed.

Regulatory and Legal Requirements: We may disclose information to regulators, law enforcement agencies, courts, or other government authorities when required by law, legal process, or to protect our legal rights.

Affiliated Companies: We may share information with our affiliated entities for purposes consistent with this Privacy Policy and applicable law.

Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, subject to applicable privacy protections.

With Your Consent: We may share information with third parties when you have provided explicit consent.

Under the Gramm-Leach-Bliley Act, you have the right to opt out of certain information sharing with non-affiliated third parties for marketing purposes. Please contact us to exercise this right.

We implement comprehensive administrative, technical, and physical safeguards to protect your personal information against unauthorized access, use, disclosure, alteration, or destruction. Our security measures include:

Encryption of sensitive data in transit and at rest using industry-standard protocols (TLS 1.3, AES-256). Multi-factor authentication for all system access. Regular security assessments and penetration testing. Employee training on data privacy and security. Physical security controls at our offices and data centers. Incident response procedures for potential data breaches.

While we employ robust security measures, no method of transmission over the internet or electronic storage is 100% secure. In the event of a security breach that compromises your personal information, we will notify you as required by applicable law.

Depending on your jurisdiction, you may have the following rights regarding your personal information:

Access: The right to request a copy of the personal information we hold about you.

Correction: The right to request correction of inaccurate or incomplete personal information.

Deletion: The right to request deletion of your personal information, subject to certain exceptions (e.g., where we are required to retain information by law).

Opt-Out: The right to opt out of the sale of your personal information (GRANDOCEAN does not sell personal information) and certain marketing communications.

California Residents: Under the California Consumer Privacy Act (CCPA), California residents have additional rights, including the right to know about personal information collected, the right to non-discrimination for exercising privacy rights, and the right to opt out of the sale of personal information.

To exercise any of these rights, please contact our Privacy Officer at [email protected] or write to us at 1270 Avenue of the Americas, New York, NY 10020.

Our website uses cookies and similar tracking technologies to enhance your browsing experience and analyze website usage. We use the following types of cookies:

Essential Cookies: Required for the website to function properly. These cannot be disabled.

Analytics Cookies: Used to understand how visitors interact with our website. This data is aggregated and anonymous.

Preference Cookies: Used to remember your preferences and settings.

You can control cookie settings through your browser settings. However, disabling certain cookies may affect the functionality of our website. We do not use cookies for targeted advertising purposes.

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. As a registered investment adviser, we are required by SEC regulations to maintain certain records for a minimum of five years. Account records are generally retained for seven years following account closure. We may retain certain information for longer periods where required by law or where we have a legitimate business interest in doing so.

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe we have collected information from a child under 18, please contact us immediately.

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable laws, or regulatory requirements. We will notify you of material changes by posting the updated Privacy Policy on our website with a revised effective date. For significant changes, we may also notify you by email or through your account portal. Your continued use of our services after the effective date of the updated Privacy Policy constitutes your acceptance of the changes.

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact our Privacy Officer:

GRANDOCEAN FINANCIAL INVESTMENT LTD Attn: Privacy Officer 1270 Avenue of the Americas New York, NY 10020

Email: [email protected] Phone: +1 (212) 555-0100

You also have the right to file a complaint with the Federal Trade Commission (FTC) at ftc.gov or with your state's attorney general if you believe your privacy rights have been violated.