Disclosures & Privacy Policy

Last Updated: 11/15/2024

At Pomarium, protecting your privacy is a priority. Although we do not directly provide investment advice to clients, we collect certain information necessary to operate our platform for financial professionals. We are committed to confidentiality, security, and transparency about how we collect, share, and protect client information.

Types of Nonpublic Personal Information (NPI) We Collect

We collect nonpublic personal information about you that is either provided to us by your Financial Professional or obtained through your authorized input on our platform. This can include:

Personal identifiers such as name, contact information, and financial information related to investment preferences, goals, and values-based criteria. This information is shared with us by your Financial Professional to enhance the accuracy and relevance of Pomarium’s investment analysis.

Information Sharing

We share personal information for specific, limited purposes: For everyday business purposes, such as generating personalized Pomarium Output, operating our platform, maintaining secure access, and complying with legal requirements. With service providers, trusted third-party vendors assist us with data storage, technical support, and platform security, bound by strict confidentiality agreements. For legal compliance, when necessary to comply with court orders, regulatory requests, or legal investigations. Pomarium does not sell, lease, or trade your personal information for marketing purposes.

How We Protect Your Information

To secure your personal information, Pomarium follows strict protocols, including data encryption and access controls to protect data during storage and transmission, and secure network architecture designed to meet federal and industry standards for privacy and data security. We retain personal data only as long as necessary to fulfill the purposes outlined in this policy or as required by law.

Your Rights to Limit Sharing

Federal law grants certain rights to limit sharing. However, Pomarium does not share personal data with affiliates for marketing purposes or with non-affiliates, except as strictly necessary for service delivery. If you wish to opt out of any information sharing that may apply, please notify us promptly through your Financial Professional.

Key Terms

Service Providers: Third-party vendors contracted to perform essential operational tasks, bound by confidentiality. Non-affiliates: Companies not related by common ownership, including service providers.

Your privacy is essential to us. Please contact us through your Financial Professional if you have questions about this Privacy Policy. Pomarium is committed to confidentiality and ensuring the quality of our platform services in alignment with privacy standards.

California Privacy Policy

Last Updated: 11/15/2024

Pomarium, provided by Inicio Inc., is committed to protecting the privacy and rights of California residents under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). This policy outlines your rights as a California resident, the types of personal information we collect, how we use it, and your choices regarding your data.

Information We Collect

Under California law, personal information is information that identifies, relates to, or could reasonably be linked with you. Pomarium may collect the following categories of personal information for business and operational purposes: Identifiers, such as name, contact details, or other unique identifiers provided through your Financial Professional or input directly with authorization. Financial Information, such as investment preferences, values-based criteria, and goals provided to generate personalized Pomarium Output for your Financial Professional. Internet Activity related to your interactions with our Platform, such as IP address and usage data. Pomarium does not collect or store sensitive personal information such as Social Security numbers or banking information directly from consumers. However, if such information were to be collected in the future, you have the right to limit its use as per CCPA/CPRA regulations.

How We Use Your Information

Pomarium uses your personal information for limited purposes, including providing services by generating customized Pomarium Output based on inputs provided by your Financial Professional, maintaining security to ensure the integrity of our Platform, and compliance with legal and regulatory obligations. We do not use your personal information for direct marketing purposes or sell it to third parties.

Your Privacy Rights

Right to Know: Request details about categories and specific pieces of personal information collected, sources, purpose of collection, and third parties shared with. Right to Delete: Request deletion of your data, with exceptions permitted by law. Right to Correct: Request correction of inaccurate data. Right to Opt-Out: Opt out of any future non-essential sharing of your information. Right to Limit Use: Limit the use of sensitive personal information if applicable.

Exercising Your Rights

To exercise your privacy rights, you or an authorized representative may contact us via Email: info@getpomarium.com with the subject line “California Privacy Rights Request” or Mail: Inicio Inc. dba Pomarium, 320 East Vine Drive, Suite 120, Fort Collins, CO 80524. We will confirm receipt of your request within 10 days and respond within the time frames required by California law. In some cases, we may request additional information to verify your identity and fulfill your request.

Non-Discrimination

We do not discriminate against California residents for exercising their CCPA/CPRA rights.

Policy Updates

We may update this policy periodically to reflect changes in legal requirements or our privacy practices. We will notify you of significant changes.

Contact Us

Inicio Inc. dba Pomarium, 320 East Vine Drive, Suite 120, Fort Collins, CO 80524

info@getpomarium.com

We value your privacy and are committed to providing transparency and control over your personal information.