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Holistic Capital LLC Privacy Policy

  1. Introduction

Holistic Capital LLC is dedicated to protecting the privacy and confidentiality of our clients’ non-public personal information. This Privacy Policy outlines our practices regarding the collection, use, and protection of information and our commitment to safeguarding client data.

  1. Information We Collect

We collect non-public personal information about clients from the following sources:

  • Information provided by the client on applications, account forms, and other documents (e.g., name, address, social security number, income, assets, and investment experience).
  • Information about client transactions with us or third parties (e.g., account activity, balances, and trading history).
  • Information received from external sources such as custodians, financial institutions, and investment managers.
  1. How We Use Client Information

Holistic Capital LLC uses client information to:

  • Provide investment advisory services tailored to the client’s financial goals and needs.
  • Process transactions and maintain accurate records of client accounts.
  • Communicate with clients about their accounts, investment strategies, and related services.
  • Comply with regulatory requirements and legal obligations.
  1. Information Sharing and Disclosure

Holistic Capital LLC does not disclose non-public personal information about current or former clients to non-affiliated third parties, except as required by law or with the explicit consent of the client. We may disclose information in the following circumstances:

  • To comply with applicable laws, regulations, or legal processes (e.g., subpoenas or court orders).
  • To trusted service providers involved in servicing client accounts, such as custodians or financial institutions, but only under strict confidentiality agreements.
  • With the client’s written consent for specific transactions or services.
  1. Protecting Client Information

Holistic Capital LLC takes the following measures to safeguard client data:

  • Physical Security: Restricted access to offices and secure storage of paper records containing client information.
  • Cybersecurity Measures: Use of encryption, firewalls, and multi-factor authentication to protect electronic client data from unauthorized access.
  • Employee Training: Regular training for employees on privacy practices, data security, and protocols to prevent data breaches.
  1. Opt-In Requirement for Information Sharing

As required by 950 Mass. Code Regs. 12.205(9)(c)13, Holistic Capital LLC operates under an “opt-in” policy for sharing non-public personal information. Clients must provide written consent before their information is shared with any non-affiliated third parties.

  1. Client Rights and Access to Information

Clients have the right to:

  • Access their personal information maintained by Holistic Capital LLC.
  • Request corrections or updates to inaccurate information.
  • Withdraw consent for sharing information with third parties at any time by contacting us.
  1. Changes to the Privacy Policy

Holistic Capital LLC reserves the right to modify this Privacy Policy at any time. Clients will be notified of any significant changes, and an updated version will be made available on our website or upon request.

  1. Contact Information

For questions regarding this Privacy Policy or to exercise your rights under this policy, please contact Holistic Capital LLC at: