Legal

Privacy
Policy

RADIANX CAPITAL, LLC is committed to protecting the privacy and confidentiality of personal information entrusted to it by clients, prospective clients, and visitors to this website. This Privacy Policy explains how we collect, use, share, and protect that information.

Effective Date: January 1, 2025  ·  Last Reviewed: January 2025
Collection Use Sharing Security Your Rights Cookies Contact
01

Information We Collect

We collect personal information in the ordinary course of providing investment advisory services and operating our website. The categories and sources of information we collect are described below.

Information provided directly by you
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Identity Information: Full name, date of birth, Social Security number or Tax Identification Number, government-issued identification.
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Contact Information: Mailing address, email address, telephone number.
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Financial Information: Account numbers, asset values, income, net worth, tax records, investment experience, risk tolerance, and financial objectives.
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Transaction Information: Records of transactions in your accounts, including purchases, sales, transfers, and distributions.
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Communication Records: Records of correspondence and meeting notes exchanged between you and RADIANX CAPITAL personnel.
Information collected automatically via website
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Usage Data: Pages visited, time on page, referring URLs, browser type, operating system, and device identifiers.
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Log Data: IP address, access timestamps, and server log data generated when you access our website.
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Cookie Data: Information stored in cookies and similar technologies, as described in the Cookies section below.
Information received from third parties
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Custodians and Brokers: Account statements, trade confirmations, and other records from financial institutions that hold your assets.
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Public Sources: Publicly available information relevant to providing advisory services, such as public records and regulatory filings.
02

How We Use Your Information

We use personal information only for lawful purposes directly related to our advisory services and business operations. We do not use personal information for purposes incompatible with those for which it was originally collected without your consent.

Purpose
Lawful Basis
Examples
Providing Advisory Services
Contractual obligation
Portfolio management, financial planning, investment recommendations
Regulatory Compliance
Legal obligation
AML/KYC, SEC reporting, Form ADV maintenance
Account Administration
Contractual obligation
Account opening, billing, record-keeping, correspondence
Communication
Legitimate interest
Responding to enquiries, account updates, regulatory notices
Service Improvement
Legitimate interest
Website analytics, platform feature improvement
Fraud Prevention
Legal obligation / Legitimate interest
Identity verification, suspicious activity monitoring
No Sale of Personal Information

RADIANX CAPITAL, LLC does not sell, rent, or otherwise transfer personal information to third parties for their marketing purposes. Personal information is used exclusively as described in this Privacy Policy.

03

How We Share Information

We may disclose personal information to third parties in limited circumstances as described below. In all cases, we require third parties to handle personal information consistently with this Policy and applicable law.

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Custodians and Broker-Dealers: We share account information with the financial institutions that custody your assets and execute transactions on your behalf.
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Service Providers: Third-party vendors including technology providers, compliance consultants, and administrators who process personal information on our behalf under written data processing agreements.
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Professional Advisers: With your consent, we may share information with your attorneys, accountants, or other professionals involved in your financial planning.
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Regulatory and Legal Requirements: We may disclose personal information to regulators, law enforcement, or courts when required by applicable law, regulation, or governmental request.
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Business Transfers: In connection with a merger, acquisition, or sale of assets, personal information may be transferred to a successor entity. We will notify affected clients prior to any such transfer.

We do not share personal information with unaffiliated third parties for their own marketing or commercial purposes without your explicit consent.

04

Information Security

We maintain a comprehensive information security programme designed to protect personal information from unauthorised access, disclosure, alteration, and destruction.

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Technical Safeguards: Encryption of data in transit (TLS) and at rest, secure access controls, multi-factor authentication, and regular security assessments.
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Physical Safeguards: Restricted office access, secure disposal of paper records, and locked storage for sensitive documents.
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Administrative Safeguards: Privacy training for all personnel, written information security policies, access controls based on need-to-know, and regular policy review.
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Incident Response: A written incident response plan governing notification and remediation in the event of a data security breach, consistent with applicable notification laws.
Security Limitation

No security system is impenetrable. We cannot guarantee the absolute security of information transmitted over the internet. We encourage clients to use strong passwords, protect their login credentials, and notify us immediately if they suspect unauthorised access to their account.

05

Data Retention

We retain personal information for as long as necessary to fulfil the purposes described in this Policy, to comply with legal and regulatory obligations, and to resolve disputes.

Category
Retention Period
Regulatory Basis
Client Account Records
5 years after termination
SEC Rule 204-2
Transaction Records
5 years from transaction date
SEC Rule 204-2
Written Communications
5 years
SEC Rule 204-2
Website & Enquiry Data
2 years from last interaction
Legitimate interest
Tax & Compliance Records
7 years minimum
IRS / state law

Following the applicable retention period, personal information is securely destroyed in accordance with our data disposal procedures.

06

Your Privacy Rights

Subject to applicable law, you have certain rights with respect to your personal information. These rights may vary depending on your state of residence.

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Right to Access: Request a copy of the personal information we hold about you, including how it is being used.
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Right to Correction: Request correction of inaccurate or incomplete personal information. We encourage clients to notify us promptly of any changes.
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Right to Deletion: In certain circumstances, request deletion of your personal information, subject to applicable retention requirements.
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Right to Opt Out of Sharing: Direct us not to share your personal information with unaffiliated third parties for marketing purposes. We do not engage in such sharing.
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Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.
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California Residents (CCPA/CPRA): Additional rights including the right to know, delete, correct, and opt out of the sale or sharing of personal information.
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Vermont Residents: Consistent with Vermont's financial privacy law, we will not disclose non-public personal information to nonaffiliated third parties except as permitted by law or with prior consent.

To exercise any of these rights, contact us using the information in the Contact section. We will acknowledge receipt within 10 business days and respond fully within the timeframe required by applicable law.

07

Cookies & Tracking
Technologies

Our website uses cookies and similar tracking technologies to improve your browsing experience, analyse website usage, and support website functionality.

Cookie Type
Purpose
Duration
Strictly Necessary
Required for basic website functionality; cannot be disabled
Session
Analytics
Understanding usage patterns to improve content and user experience
Up to 2 years
Preference
Remembering your settings and preferences for future visits
Up to 1 year

You can control cookies through your browser settings. Disabling cookies may affect the functionality of certain parts of our website. We do not use cookies for advertising or cross-site tracking purposes.

Do Not Track

Our website does not currently respond to "Do Not Track" browser signals, as there is no industry-wide standard for compliance. We will update this policy if a recognised standard is established.

08

Third-Party Links

Our website may contain links to third-party websites, including the SEC's IAPD system, financial data providers, and other external resources. This Privacy Policy applies only to radianx.io and information collected directly by RADIANX CAPITAL, LLC.

We are not responsible for the privacy practices of third-party websites. We encourage you to review the privacy policies of any third-party website you visit through links on our site. Inclusion of a link does not constitute an endorsement of that third party's privacy practices.

09

Children's Privacy

Our website and services are intended for adults only. We do not knowingly collect personal information from individuals under the age of 18. If you believe that a minor has provided us with personal information without parental consent, please contact us immediately and we will take steps to delete such information promptly.

10

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or regulatory requirements. When we make material changes, we will:

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Update the "Last Reviewed" date at the top of this policy
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Post the updated policy at radianx.io/privacy
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Notify existing clients in writing if changes materially affect how we use their personal information

Your continued use of our website or advisory services following the effective date of any updated policy constitutes your acceptance of the changes.

This Privacy Policy is provided in compliance with Regulation S-P (Privacy of Consumer Financial Information) under the Securities Exchange Act of 1934, and applicable state privacy laws including the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). Last reviewed January 2025.

11

Privacy Contact

For questions about this Privacy Policy, to exercise your privacy rights, or to make a privacy-related request, please contact us using the information below.

Privacy Officer
RADIANX CAPITAL, LLC
Attn: Privacy Officer
Mailing Address
529 5th Avenue, Suite 1475
New York, NY 10017
Email
[email protected]
Telephone
(646) 403-3807

You also have the right to file a complaint with your applicable state privacy regulator or the U.S. Federal Trade Commission if you believe your privacy rights have been violated. We encourage you to contact us first so that we have an opportunity to address your concern directly.

Questions about
how we handle
your information?

We take privacy seriously and welcome your questions. Reach out to our privacy team directly — we respond to all enquiries promptly and with complete transparency.

Email Privacy Team General Contact

RADIANX CAPITAL, LLC is an SEC-registered investment adviser (CRD# 298178 · SEC# 801-117100). This Privacy Policy is provided pursuant to Regulation S-P and applicable state privacy laws including CCPA/CPRA. © 2025 RADIANX CAPITAL, LLC. All rights reserved.

radianx.io/privacy