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Privacy Policy

Last updated: January 1, 2025

Divergent Capital Asset Management LLC ("Divergent," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you visit our website or engage with our services.

1. Information We Collect

We may collect the following categories of personal information:

  • Contact Information: Name, email address, phone number, and mailing address provided when you contact us or submit an inquiry.

  • Professional Information: Firm name, title, assets under management, and investment preferences relevant to our advisory services.

  • Usage Data: Information about how you access and use our website, including IP address, browser type, pages viewed, and time spent on pages.

  • Financial Information: Information required to provide investment advisory services, including accredited investor status and investment objectives, collected pursuant to regulatory requirements.

2. How We Use Your Information

We use the information we collect to:

  • Provide, operate, and improve our investment advisory and fund operations services

  • Respond to inquiries, service requests, and communications

  • Comply with applicable laws, regulations, and regulatory obligations, including SEC and FINRA requirements

  • Send informational communications about our services, market updates, and firm news, where permitted by law

  • Protect the security and integrity of our platform and services

3. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information with:

  • Service Providers: Third-party vendors who assist in operating our business, subject to confidentiality obligations.

  • Regulatory Authorities: As required by law, court order, or regulatory requirement, including the SEC, FINRA, or other applicable authorities.

  • Business Transfers: In connection with a merger, acquisition, or sale of all or a portion of our assets, with appropriate confidentiality protections.

4. Data Security

We implement commercially reasonable technical, administrative, and physical safeguards to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

5. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to enhance user experience, analyze usage patterns, and improve our services. You may adjust your browser settings to refuse cookies, though this may affect certain functionality of our site.

6. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights with respect to your personal information, including the right to access, correct, or request deletion of your data. To exercise any of these rights, or to opt out of marketing communications, please contact us at:

Divergent Capital Asset Management LLC

3300 PGA Blvd, Suite 570, Palm Beach Gardens, FL 33410

Phone: 800.305.3221

Subject line: "Privacy Request"

7. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website with a revised effective date. Your continued use of our website following any changes constitutes your acceptance of the updated policy.

This Privacy Policy is provided for informational purposes only and does not constitute legal advice. Divergent Capital Asset Management LLC is a registered investment adviser. Registration does not imply a certain level of skill or training.