Privacy Policy

1. Introduction

CleverAlpha Securities (a DBA of Velocity Capital LLC) and CleverAlpha Asset Management LLC (“CleverAlpha,” “we,” “our,” or “us”) are committed to protecting your personal information. This Privacy Policy describes how we collect, use, share, and safeguard information we obtain through our websites (cleveralphasecurities.com and CDexplorer.com), our online brokerage and advisory platforms, and any related services (collectively, the “Services”).

By accessing or using our Services, you agree to this Privacy Policy. If you do not agree, please discontinue use of our Services.

2. Information We Collect

Information You Provide Directly

• Identity information: full name, date of birth, Social Security Number or Tax Identification Number, government-issued ID
• Contact information: mailing address, email address, phone number
• Financial information: income, net worth, investment objectives, bank account and routing numbers, existing brokerage account details
• Employment information: employer name, occupation, whether you are affiliated with a FINRA member firm
• Communications: messages you send to our support team, survey responses, feedback

Information Collected Automatically

• Log data: IP address, browser type and version, pages visited, time and date of visit, referring URL
• Device data: device type, operating system, unique device identifiers
• Usage data: features accessed, transactions initiated, clicks, session duration
• Cookies and similar technologies: session cookies, persistent cookies, web beacons, pixel tags (see Section 6)

Information from Third Parties

• Identity verification providers for KYC/AML compliance
• Credit bureaus and background check services
• Bank account verification services (e.g., Plaid or similar)
• FINRA BrokerCheck and regulatory databases

3. How We Use Your Information

• Account opening and maintenance: To verify your identity, open brokerage or advisory accounts, and maintain accurate records
• Regulatory compliance: To satisfy our obligations under FINRA rules, SEC regulations, the Bank Secrecy Act, anti-money laundering laws, and other applicable regulations
• Transaction processing: To execute trades, process CD purchases and sales, and settle transactions
• Communications: To send account statements, trade confirmations, tax documents, disclosures, and important notices
• Service improvement: To analyze usage patterns, develop new features, and improve our platforms
• Marketing: To send promotional communications about our services (you may opt out at any time)
• Security: To detect, prevent, and investigate fraud, unauthorized access, and other harmful activity
• Legal obligations: To respond to legal process, regulatory inquiries, and court orders

4. How We Share Your Information

We do not sell your personal information. We may share information with:

• Regulatory bodies: FINRA, SEC, SIPC, FDIC, and other regulators as required by law
• Introducing/clearing relationships: Velocity Clearing LLC and other clearing firms for trade settlement and custody
• Service providers: Third-party vendors who perform services on our behalf (technology, data storage, identity verification, payment processing) under confidentiality agreements
• Affiliated entities: Between CleverAlpha Securities and CleverAlpha Asset Management for account management and compliance purposes
• Legal requirements: When required by law, subpoena, court order, or to protect the rights and safety of CleverAlpha, our customers, and the public
• Business transfers: In connection with a merger, acquisition, or sale of assets, subject to standard confidentiality protections

5. Data Retention

We retain personal information for as long as necessary to provide our Services and comply with legal and regulatory obligations. Brokerage records are subject to FINRA Rule 4511 and SEC Rule 17a-4, which require retention of certain records for a minimum of three to six years. Account information is generally retained for seven years after account closure. You may request deletion of certain non-regulated personal data; however, we may be required by law to retain certain records.

6. Cookies & Tracking Technologies

We use cookies and similar technologies to operate and improve our Services. Types of cookies we use:

• Strictly necessary: Required for authentication, security, and basic site functionality
• Performance/analytics: To understand how visitors use our site (e.g., Google Analytics)
• Functional: To remember your preferences and settings
• Marketing: To deliver relevant advertising (you may opt out via your browser settings or industry opt-out tools)

You can control cookie settings through your browser. Disabling certain cookies may affect site functionality.

7. Your Rights

California Residents (CCPA/CPRA)

If you are a California resident, you have the right to: (1) know what personal information we collect and how it is used; (2) delete personal information we hold about you, subject to certain exceptions; (3) opt out of the sale or sharing of your personal information (we do not sell personal information); (4) non-discrimination for exercising your rights; and (5) correct inaccurate personal information.

All Users

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Opt-out of marketing: Unsubscribe from promotional emails at any time using the link in any email or by contacting us

To exercise your rights, contact us at privacy@cleveralpha.com.

8. Data Security

We implement industry-standard technical and organizational measures to protect your information, including TLS/SSL encryption for data in transit, AES-256 encryption for data at rest, multi-factor authentication, network segmentation, and regular security assessments. However, no method of transmission over the internet or electronic storage is 100% secure. We encourage you to use strong passwords and contact us immediately if you suspect unauthorized access to your account.

9. Children’s Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected information from a child under 18, we will delete it promptly. Contact us at privacy@cleveralpha.com if you believe we have inadvertently collected such information.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or a prominent notice on our website at least 30 days before they take effect. Continued use of our Services after changes take effect constitutes your acceptance of the revised policy.

11. Contact Us

For privacy-related questions or to exercise your rights:
CleverAlpha Securities / Velocity Capital LLC
199 Water Street, 8th Floor, New York, NY 10038
Email: privacy@cleveralpha.com
Support: support@cleveralpha.com