Privacy Policy

Last Updated: 3/18/2025

Your privacy is very important to us and we take your privacy very seriously. This Privacy Policy describes how Morangie Management LLC (“Company”, “we”, “us”, or “our”) collects and uses the personal information you provide to us on our website and all other websites, mobile sites, applications, platforms and tools where this Privacy Policy appears or is linked, and through the use of our services, (collectively the “Site”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

By creating an account, providing information to us (by any means, whether in correspondence, via our Site, or otherwise), or continuing to use our services, you acknowledge that you have read, understood, and consent to be bound by this Privacy Policy.

If you do not agree with this PRIVACY Policy or our practices, you may not use our SITE. This PRIVACY Policy may change from time to time and your continued use of our SITE constitutes your acceptance of those changes. We encourage you to review this PRIVACY Policy periodically.

1. Personal Information We Collect About You.

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”):

Category A – Identifiers

Collected: Yes
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Category B - Customer records information (i.e. Information that identifies, relates to, describes, or is capable of being associated with, a particular individual)

Collected: Yes
Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Category C - Characteristics of protected classifications under state or federal law

Collected: No
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Category D - Commercial information

Collected: Yes, only through our client login portal related to stock and investment history
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Category E - Biometric information

Collected: No
Retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry.

Category F - Internet or other electronic network activity information

Collected: Yes
Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.

Category G - Geolocation data

Collected: No
Physical location or movements

Category H - Sensory data

Collected: No
Audio, electronic, visual, thermal, olfactory, or similar information.

Category I - Professional or employment-related information.

Collected: No
Place of employment, position, job history, salary, resume, and other related data.

Category J - Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)

Collected: No
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Category K - Sensitive personal information

Collected: Yes, only through our client login portal related to bank and financial account information you provide
(1) personal information that reveals: A person’s social security, driver’s license, state identification card, or passport number; A person’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; A person’s precise geolocation; A person’s racial or ethnic origin, religious or philosophical beliefs, or union membership; The contents of a person’s mail, email, and text messages unless the business is the intended recipient of the communication; or A person’s genetic data. (2) the processing of biometric information for the purpose of uniquely identifying a consumer; (3) personal information collected and analyzed concerning a consumer’s health, or a personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

Category L - Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No
An inference is essentially a characteristic deduced about a consumer (such as ‘married,’ ‘homeowner,’ ‘online shopper,’ or ‘likely voter’) that is based on other information a business has collected.

This personal information is required to provide products or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products or services to you.

2. Cookies and Other Tracking Technologies.

Cookies are small text files of information stored by the Internet browser on your computer’s hard drive. We may use these cookies to collect browsing data to keep track of your preferences and profile information and to collect general usage and volume statistical information. Our cookies do not collect personal or confidential information and are not spyware.

There are a number of different types of cookies, however, our Site uses:

Essential – These cookies are necessary to the core functionality of our Site and some of its features, such as access to secure areas.
Performance and Functionality – These cookies are used to enhance the performance and functionality of our Site. For example, we may use these cookies so that we recognize you on our Site and remember your previously selected preferences. These could include what language you prefer and your geographic location. These cookies are nonessential to the use of our Site, however, without these cookies, certain functionality may become unavailable. A mix of first-party and third-party cookies are used.
Advertising or Marketing – These cookies are used to make advertising messages more relevant to you. They prevent the same ad from continuously reappearing, ensure that ads are properly displayed for advertisers, and in some cases select advertisements that are based on your interests. Our Company sometimes shares online data collected through these cookies with our advertising partners. This means that when you visit another Site, you may be shown advertising based on your browsing patterns on our Site.
Analytics and Customization –Our Company uses these cookies and technologies to analyze how the Site is accessed, used, or performing in order to improve your user experience and to maintain, operate and continually improve the Site. For example, we use Google Analytics on the Site to collect: page url/page title and user browser/system information, which includes browser type, referrer, language, java/flash support, IP address, and ad-serving data. For information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, visit Google’s “How you can control the information collected by Google on these sites and apps” article available here.
Unclassified – These are cookies that have not yet been categorized. We are in the process of classifying these cookies with the help of their providers.

Web Beacons

Our Site contains electronic images known as web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns. We use a third party to gather information about how you and others use our Site. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our Site is used.

How to Manage Cookies.

You have the right to decide whether to accept or reject certain cookies. You can set your browser not to accept cookies and you can remove cookies from your browser. However, in a few cases, some of our Site features may not function as a result. Essential cookies cannot be rejected, as they are strictly necessary to provide you with our Site.

3. Do Not Track/Global Privacy Controls

'Global Privacy Control' (GPC) is a browser setting that allows users to automatically communicate their preference to opt out of data sharing or selling across different websites. When you enable a GPC setting in your web browser, you are signaling to websites that you wish to opt out of the sale or sharing of your personal information across all websites that recognize this signal. We do not currently support the GPC mechanism.

4. Promotional Communications.

We may use your personal information to send you updates (by email, text message, telephone or post) about our products or services, including exclusive offers, promotions or new products or services.

We have a legitimate interest in processing your personal information for promotional purposes (see below “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it to other third party organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

Contacting us by using one of the methods listed in the “How to Contact Us” Section below; or
Using the “unsubscribe” link in emails or “STOP” number in texts.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

5. How Your Personal Information is Collected.

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our Site. However, we may also collect information:

From third parties (e.g. through referrals)
From publicly accessible sources (e.g., property records);
From cookies on our Site; and
Via our IT systems, including automated monitoring of our Site and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

6. How and Why We Use Your Personal Information.

We may use (process) your personal information for the following purposes:

To provide our Site, our products and our services to you;
To prevent and detect fraud against you or Company;
To comply with professional, legal and regulatory obligations that apply to our business, e.g. under rules issued by our professional regulator];
Ensuring business policies are adhered to, e.g. policies covering security and internet use;
Operational reasons, such as improving efficiency, training and quality control;
Ensuring the confidentiality of commercially sensitive information;
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures;
Preventing unauthorized access and modifications to systems;
Updating and enhancing customer records;
Ensuring safe working practices, staff administration and assessments; and
Marketing our services to:
- existing and former customers;
- third parties who have previously expressed an interest in our services;
- third parties with whom we have had no previous dealings.

We may also anonymize, aggregate or de-identify personal information so the end-product does not identify you or any other individual. For example, we may use this information to generate norms by industry, geography, level, etc., enable us to understand where our services are being utilized, conduct ongoing validation studies, compile reports, and improve the services. Such aggregated, anonymized or de-identified information is not considered personal information for purposes of this Privacy Policy and we may use it for any purpose.

7. Who We Share Your Personal Information With.

We may share personal information with:

Our Business Partners. We may disclose your personal information to other companies with whom we partner to provide the Site and our services, to promote our products, services, offers, and to carry out other activities described in this Privacy Policy.
Our Service Providers. We may disclose your personal information to third parties that provide business, professional, or technical support services to us and/or administer activities on our behalf.
Our Analytics Providers. We may disclose your personal information to parties that assist us in performing analytics and help us measure the effectiveness of the Site and our marketing and advertising efforts.
Governmental and Public Authorities. We may disclose your personal information to government and public authorities as necessary or permitted by the laws of any jurisdiction in which we operate, including in response to a subpoena, court order, investigative demand, request for cooperation from a law enforcement agency, or similar request from a self-regulatory body or government agency.
Relevant Third Parties in Connection with a Business Transaction. We may disclose or otherwise transfer your personal information to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction as well as in the event of any insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.

We may also need to share some personal information with other parties to the extent we believe it is necessary or appropriate to (1) protect our operations and those of our affiliates and subsidiaries; (2) investigate and prevent against fraud and other illegal activity; (3) protect our rights, privacy, safety, property, and/or those of others; or (4) allow us to pursue available remedies or limit damages that we may sustain.

We may disclose your personal information for other reasons described at the time of information collection or prior to disclosing your information. Additionally, we may disclose your personal information with your consent or when you direct us to do so.

Except as set forth above, we will not share your personal information with any other third party.

8. How Long Your Personal Information Will Be Kept.

We will keep your personal information while you have an account with us or while we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly;
To improve our security or detect and prevent fraud; or
To comply with legal or regulatory obligations or to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of personal information; the potential risk from unauthorized use or disclosure of the personal information; the purpose(s) for which we use or may use the personal information; whether we can achieve the purpose(s) through other means; and the applicable legal requirements.

9. Children and our Site.

Our Site is not directed to children, and you may not use our Site if you are under the age of 18. If you are under 18, do not use our services, access the Site, or provide any information about yourself including, without limitation, your name, address, email address or any screen name or user name you may use. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, in compliance with the Children’s Online Privacy Protection Act, we will purge such information from our database and cancel the corresponding accounts. If you believe we may have any information from or about a child under 13, please see our “How to Contact Us” Section below. Please visit the FTC's website at www.ftc.gov for tips on protecting children's privacy online.

10. Keeping Your Personal Information Secure.

We use reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction. We endeavor to protect the personal information we receive, gather and store, by such means as password protection, firewalls and other means.

Please note, however, no system can be completely secure and transmissions over the internet are never entirely secure. Therefore, although we take steps to secure your information, we cannot guarantee your information, searches, or other communications will always remain secure. Any such transmission of information by you over the internet is at your own risk.

11. Other California Privacy Right

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email using contact information provided in this Privacy Policy.

12. A Note to Users Outside of the United States.

Company is headquartered in the United States and utilizes service providers in the United States. The Site is not intended for Site visitors outside the United States. If you are a non-U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your personal information may be processed for the purposes identified in this Privacy Policy. If you choose to access our Site outside the United States, Company and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. In particular, you are advised that the United States uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Where the laws of your country allow you to do so, by using the Site or the services or by providing your data, you consent and authorize Company to transfer, store, and use all such personal information in the United States (and any other country where we operate) which may not offer an equivalent level of protection to that required in the country where you reside and to the processing of that personal information by us on our servers located in the United States, as described in this Privacy Policy. If you do not want your personal information transferred to the United States and any other country where we operate, please do not submit any information to us or use our Site or the services.

13. Third Party Websites.

If, in your interactions with the Site, you are linked or directed to, or click on, a third-party website, we cannot control what information you may provide to that party or on that website, and we are not responsible for how that party may use or disclose any information you may provide to them. This is not as an endorsement by us of any third-party website, content that may be offered on such third-party website, or of any products or services provided by such third party. We do not control, nor are we responsible for, such third-party website, product or service offerings. As such, we urge that you exercise caution before providing them with your personal information and to review the third party’s privacy policy for information on its data processing practice.

You should contact the site administrator for such third-party website if you have any complaints, claims, concerns or questions regarding such third-party website or its privacy practices.

14. Changes to this Privacy Policy.

This Privacy Policy was published on the date “Last Updated” above.

We may change this Privacy Policy from time to time. Changes to this Privacy Policy will be made by updating this page. Please visit this Privacy Policy regularly to read the current version

15. How to Contact Us.

Please contact us if you have any questions about this Privacy Policy or the information we hold about you by email: operations@morangiellc.com .