This Privacy Policy explains how Stembassadors Capital Partners LLC and its subsidiaries and affiliated companies ("Stembassadors Capital," "we," or "us") collect, use, and disclose information about you when you access or use our websites, contact us, or otherwise interact with us.
We collect information you provide directly to us. For example, you share information directly with us when you:
The types of information we may collect include your name, email address, postal address, phone number, employment history, investment objectives, financial information, and any other information you choose to provide.
When you access or use our website, we automatically collect certain information about your device and your use of the site, including:
We may also receive information about you from third parties, including our business partners, data providers, publicly available sources, and individuals who refer you to us. We may combine this information with information we already have about you.
We use the information we collect about you for the following purposes:
We process your personal information on the legal bases of: (i) contractual necessity, where processing is required to fulfill a service agreement or pre-contractual steps; (ii) legitimate interests, such as fraud prevention and website improvement; (iii) compliance with legal obligations; and (iv) your consent, where applicable and obtained.
We may share information about you as follows or as otherwise described in this Privacy Policy:
We do not sell your personal information to third parties for their own marketing purposes.
We may allow third parties to serve analytics services and deliver advertisements on our behalf. These third parties may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our website and other websites, including your IP address, web browser, pages viewed, time spent on pages, and links clicked. This information may be used by Stembassadors Capital and third parties to deliver targeted advertisements and analyze and track data, to determine the popularity of certain content, and to better understand your online activity.
For more information about interest-based advertising, or to opt out of receiving targeted advertising from participating companies, please visit the Digital Advertising Alliance (aboutads.info) or the Network Advertising Initiative (networkadvertising.org).
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, some features of our website may not function properly.
Stembassadors Capital is headquartered in the United States, and we have operations and service providers in the United States and around the world. When we collect information from you, we may process it in the United States and other jurisdictions. By accessing our website or using our services, you acknowledge that your personal information may be transferred to and processed in the United States or other countries, which may have data protection laws that differ from those in your country of residence.
Where we transfer personal data from the European Economic Area (EEA), the United Kingdom, or Switzerland to countries not recognized as providing an adequate level of data protection, we rely on appropriate safeguards such as Standard Contractual Clauses approved by the European Commission or other legally recognized transfer mechanisms.
Stembassadors Capital takes reasonable and appropriate measures designed to protect your personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We implement physical, technical, and administrative safeguards appropriate to the sensitivity of the information we hold.
Despite these measures, no security system is impenetrable, and we cannot guarantee the security of our systems or databases. You are responsible for maintaining the secrecy of any password you use to access our services, and for taking precautions to protect your own information.
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. When determining the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, and applicable legal requirements.
We may retain certain information even after you close your account or after we stop providing services to you, to the extent we are required or permitted to do so by applicable law.
You may update or correct information associated with your account by contacting us. If you wish to delete your account, please contact us, but note that we may retain certain information as required by law or for legitimate business purposes.
You may opt out of receiving marketing and research communications from us by following the unsubscribe instructions in those communications or by contacting us directly. Note that even if you opt out of marketing communications, we may still send you non-promotional communications, such as those about your account or our ongoing business relationship.
Most browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may not be able to use all features of our website.
Some browsers incorporate a "Do Not Track" (DNT) feature that signals websites not to track your activity. Our website does not currently respond to DNT signals. For more information about DNT, please visit allaboutdnt.com.
If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information. Subject to certain exceptions, you have the right to:
To exercise your California privacy rights, please contact us using the information in the Contact Us section below. We will verify your request using information you provide and will respond within the timeframes required by law.
Stembassadors Capital does not sell personal information as defined under the CCPA, and has not done so in the preceding 12 months.
If you are located in the European Economic Area (EEA) or the United Kingdom, you have certain rights under the General Data Protection Regulation (GDPR) or UK GDPR, including:
To exercise any of these rights, please contact our Data Protection Officer using the information in the Contact Us section. You also have the right to lodge a complaint with your local supervisory authority.
Our EU/UK representative for GDPR purposes is: Stembassadors Capital (UK) Ltd, 10 Grosvenor Square, London W1K 6JP, United Kingdom.
Our website and services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16 without verifiable parental consent, we will take steps to delete that information as soon as reasonably practicable. If you believe we might have any information from or about a child under 16, please contact us.
We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the revised policy on our website with a new effective date, or by other means as required by law. We encourage you to review this Privacy Policy periodically to stay informed about our information practices. Your continued use of our website after any changes to this Privacy Policy constitutes your acceptance of the updated terms.
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Stembassadors Capital Partners LLC
Attn: Privacy & Legal Department
1100 K Street NW, Suite 1200
Washington, DC 20005
United States
Email: privacy@stembassadorscapital.com
General Inquiries: Contact Form
For EEA/UK data subjects wishing to exercise GDPR rights, please include "GDPR Request" in the subject line of your email. We will acknowledge your request within 72 hours and respond within 30 days, unless an extension is required by law.