PRIVACY POLICY

Dext Capital, LLC ("Dext Capital," "we," "us," or "our") is committed to protecting the privacy and security of personal and financial information collected from our clients, prospective clients, website visitors, and business partners.

This Privacy Policy describes our practices regarding the collection, use, disclosure, and protection of information in compliance with applicable U.S. federal and state privacy laws, including but not limited to the Gramm-Leach-Bliley Act (GLBA), California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act (VCDPA), and other relevant financial services regulations.

1. Information We Collect

As a financial services firm, we collect various categories of personal and financial information necessary to provide investment and capital management services:

1.1. Personal Identifiers

• Full legal name, date of birth, and Social Security Number
• Contact information (address, email, phone numbers)
• Government-issued identification (driver's license, passport)
• Professional information and employment details

1.2. Financial Information

• Bank account information and routing numbers
• Investment account details and holdings
• Transaction history and trading activity
• Income, assets, liabilities, and net worth
• Tax identification numbers and tax-related information
• Credit reports and credit scores (when applicable)

1.3. Investment Profile Information

• Investment objectives and time horizon
• Risk tolerance and investment experience
• Financial goals and investment preferences
• Suitability and appropriateness assessments

1.4. Internet and Electronic Activity

• Website browsing behavior and interaction data
• IP address, device information, and browser type
• Login credentials and authentication data
• Cookies and similar tracking technologies

1.5. Professional and Business Information

• Business affiliations and corporate relationships
• Professional licenses and certifications
• Employment history and background

2. How We Collect Information

We collect information through various methods:

• Account Opening: Applications, forms, and onboarding documentation
• Ongoing Relationship: Account statements, transactions, and communications
• Third Parties: Credit bureaus, identity verification services, custodians, brokers, and other financial institutions
• Public Records: Publicly available databases and regulatory filings
• Website and Technology: Cookies, web beacons, and analytics tools
• Business Partners: Referral sources and professional advisors (with your consent)

3. How We Use Your Information

We use personal and financial information for the following purposes:

3.1. Service Delivery

• Opening and maintaining investment accounts
• Processing transactions and managing portfolios
• Providing investment advice and recommendations
• Executing trades and settlements
• Generating account statements and reports

3.2. Regulatory Compliance

• Verifying identity and conducting Know Your Customer (KYC) procedures
• Complying with Anti-Money Laundering (AML) regulations
• Meeting Securities and Exchange Commission (SEC) requirements
• Adhering to Financial Industry Regulatory Authority (FINRA) rules
• Fulfilling tax reporting obligations (IRS Form 1099, etc.)
• Responding to regulatory inquiries and examinations

3.3. Risk Management and Fraud Prevention

• Assessing suitability and appropriateness of investments
• Monitoring accounts for suspicious activity
• Preventing fraud, identity theft, and unauthorized access
• Conducting due diligence and background checks

3.4. Business Operations

• Communicating about accounts, services, and important notices
• Providing customer service and support
• Processing payments and managing billing
• Improving services and developing new offerings
• Conducting research and analysis

3.5. Marketing and Communications

• Sending newsletters and market updates (with consent)
• Providing educational content and resources
• Informing about new products and services

4. Information Sharing and Disclosure

We may share personal and financial information with the following parties:

4.1. Service Providers and Financial Institutions

• Custodians and Broker-Dealers: For account custody and trade execution
• Banks and Payment Processors: For financial transactions
• Technology Providers: For IT infrastructure, cloud services, and cybersecurity
• Professional Advisors: Attorneys, accountants, auditors, and consultants
• Insurance Providers: For errors and omissions coverage

4.2. Regulatory and Legal Authorities

• Securities and Exchange Commission (SEC)
• Financial Industry Regulatory Authority (FINRA)
• Internal Revenue Service (IRS)
• State securities regulators
• Law enforcement agencies (when legally required)
• Courts and legal proceedings

4.3. Business Affiliates

• Related entities within our corporate structure
• Strategic partners and joint ventures

4.4. With Your Consent

• Third-party advisors you designate
• Family members or authorized representatives
• Other parties as you direct or authorize

5. Data Security

We maintain comprehensive security measures to protect personal and financial information:

• Physical Security: Restricted access to offices, locked file cabinets, and secure facilities
• Technical Security: Encryption (SSL/TLS), firewalls, intrusion detection systems, and secure servers
• Administrative Security: Access controls, employee training, confidentiality agreements, and security policies
• Authentication: Multi-factor authentication and strong password requirements
• Monitoring: Regular security audits, vulnerability assessments, and penetration testing
• Incident Response: Breach notification procedures and incident response plan
• Vendor Management: Due diligence and security requirements for third-party providers

6. Data Retention

We retain personal and financial information for the following periods:

• Account Records: Duration of relationship plus 7 years (SEC Rule 204-2)
• Transaction Records: 6 years from transaction date (SEC and IRS requirements)
• Communications: 6 years (SEC Rule 17a-4)
• Tax Records: 7 years (IRS requirements)
• Identity Verification: 5 years after account closure (CIP requirements)
• Marketing Preferences: Until consent is withdrawn

7. Your Privacy Rights

Depending on your state of residence, you may have the following rights:

7.1. GLBA Rights (All Clients)

• Right to receive annual privacy notices
• Right to opt-out of certain information sharing
• Right to limit marketing communications

7.2. California Residents (CCPA/CPRA)

• Right to Know: Request disclosure of information collected and shared
• Right to Delete: Request deletion of personal information (subject to legal and regulatory exceptions)
• Right to Correct: Request correction of inaccurate information
• Right to Opt-Out: Opt-out of sale or sharing (we do not sell information)
• Right to Limit: Limit use of sensitive personal information
• Right to Non-Discrimination: Exercise rights without penalty

7.3. Virginia, Colorado, Connecticut, Utah Residents

• Right to access personal information
• Right to correct inaccuracies
• Right to delete personal information
• Right to opt-out of targeted advertising
• Right to data portability

7.4. How to Exercise Your Rights

To exercise your privacy rights or opt-out of marketing communications, please contact us using the information in Section 14. We will respond to verifiable requests within 45 days.

Important Note: Some requests may be subject to exceptions under financial services regulations. We will explain any limitations when responding to your request.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies:

8.1. Types of Cookies

• Essential Cookies: Required for website functionality and security
• Analytics Cookies: Help us understand website usage and performance
• Functionality Cookies: Remember preferences and settings
• Marketing Cookies: Deliver relevant content (with consent)

8.2. Managing Cookies

You can control cookies through browser settings. Note that disabling certain cookies may affect website functionality and your ability to access secure areas.

9. Do Not Track Signals

Our website does not currently respond to "Do Not Track" browser signals. We comply with applicable privacy laws regarding tracking and targeted advertising.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect information from minors. Investment accounts for minors are managed by legal guardians.

12. International Data Transfers

We primarily operate within the United States. If we transfer information internationally, we ensure appropriate safeguards are in place to protect your information.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, services, or applicable laws. Material changes will be communicated through:

• Updated policy posted on our website with revised date
• Email notification to clients (when required)
• Annual privacy notice delivery

14. Contact Information

For questions about this Privacy Policy, to exercise your privacy rights, or to update your information, please contact us:

15. Regulatory Compliance

15.1. Securities Laws

We comply with SEC regulations, including Investment Advisers Act of 1940, and maintain records as required by SEC Rule 204-2.

15.2. Anti-Money Laundering (AML)

We adhere to Bank Secrecy Act requirements, USA PATRIOT Act provisions, and FINRA AML rules, including Customer Identification Program (CIP) requirements.

15.3. Financial Privacy

We comply with Gramm-Leach-Bliley Act (GLBA) requirements for financial institutions, including Regulation S-P privacy provisions.

15.4. State Regulations

We comply with applicable state securities laws and privacy regulations where we conduct business.

16. Safeguard Procedures

In accordance with GLBA Safeguards Rule, we maintain a comprehensive information security program that includes:

• Designated security coordinator and oversight
• Risk assessment and management processes
• Employee training and awareness programs
• Service provider due diligence and oversight
• Regular testing and monitoring of security controls
• Incident response and business continuity plans
• Periodic program evaluation and updates

17. Client Relationship Summary (Form CRS)

For information about our services, fees, conflicts of interest, and legal standards of conduct, please refer to our Form CRS (Client Relationship Summary) available on our website or upon request.

Effective Date: January 1, 2026

Version: 1.0

← Back to Website