1.Introduction
This Privacy Policy (“Policy”) describes how Glidepath Fund GP Services, LLC (“Glidepath,” “we,” “us,” or “our”) and its affiliates (collectively, the “Glidepath Companies”) collect, use, share, and protect personal information about our current, prospective, and former customers, website visitors, and other individuals who interact with us.
This Policy applies to information we collect generally through www.glidepath.ai (the “Site”), through our mobile and web applications, when you open or maintain a user account with us or when you otherwise communicate with us. Use of specific services offered by any Glidepath Companies, including brokerage services, investment advisory services, and aircraft charter services, is governed by separate written customer or client agreements (each, a “Client Agreement”). In the event of a conflict between this Policy and a Client Agreement, the Client Agreement controls with respect to that service.
By using our Site or services, you acknowledge that you have read and agreed to all the terms of this Policy.
2.Information We Collect
The categories of personal information we collect depend on the services you request, your relationship with us, and how you interact with our Site. We collect information from the following categories:
2.1 Identifiers and Contact Information
Name, mailing and email addresses, telephone numbers, date of birth, government-issued identification numbers (including Social Security number or taxpayer identification number), passport, driver’s license number, and online identifiers.
2.2 Online and Device Information
IP address, browser type, device identifiers, operating system, referring URLs, pages viewed, time spent on the Site, and information collected through cookies, pixels, and similar technologies (see Section 8).
2.3 Sensitive Personal Information
Some of the information we collect is treated as “sensitive personal information” under applicable law. We use sensitive personal information only for the purposes described in Section 4 and as otherwise permitted by law. We do not use or disclose sensitive personal information to infer characteristics about you.
2.4 Information from Third Parties
We may receive information about you from your employer or plan sponsor, custodians, clearing firms, joint account holders, banks, credit bureaus, identity-verification and fraud-prevention vendors, regulators, public databases, and our affiliates. For Craft Charter, we may receive information from travel agents, travel-management companies, and aircraft owners participating in management or charter programs.
3.Sources of Personal Information
We collect personal information from the following sources:
- Directly from you, including in account-opening applications (paper or electronic), client agreements, surveys, and your communications with us.
- Automatically through your use of the Site or our applications.
- From our affiliates and from non-affiliated third parties including social media partners and service providers.
4.How We Use Personal Information
We use personal information for the following business purposes:
- To open, maintain, and service your accounts and to process your transactions, including securities trades, advisory transactions, and charter flight bookings.
- To verify your identity and to comply with anti-money-laundering, know-your-customer, sanctions, customer due-diligence, and counter-terrorism financing laws.
- To comply with our legal, regulatory, recordkeeping, and reporting obligations under applicable laws.
- To detect, investigate, and prevent fraud, security incidents, and other unlawful or harmful activity, and to safeguard our customers, employees, and assets.
- To communicate with you about your account, your transactions, our services, and changes to our policies and disclosures.
- To provide customer support and to respond to your questions, complaints, and requests.
- To operate, maintain, and improve our Site, applications, and services, including for analytics, debugging, and product development.
- With your consent, to send you marketing communications about products and services that may be of interest to you. You may opt out of marketing communications at any time.
- To enforce our agreements with you, defend against legal claims, and otherwise protect our rights, property, and interests.
6.How We Protect Your Information
It is our policy not to release your personal information except as permitted by law, with your consent, as requested by you, or as set forth in this Policy. Within the Glidepath Companies, we restrict access to your personal information to those employees, agents, and service providers who require it to provide products or services to you. To protect your personal information from unauthorized access and use, we maintain administrative, technical, and physical safeguards designed to comply with applicable federal and state laws.
7.Data Retention
We retain personal information for as long as necessary to provide our services and to comply with our legal, regulatory, accounting, recordkeeping, and reporting obligations. Once retention is no longer required, we securely delete, de-identify, or anonymize the information.
9.Your California Privacy Rights (CCPA / CPRA)
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), provides you with specific rights regarding your personal information. This section applies only to personal information that is not subject to the GLBA exemption (i.e., information collected outside of the financial-services context, such as Site-visitor or marketing-related data).
9.1 Categories of Personal Information We Collect, Disclose, and Retain
Within the prior 12 months, we have collected, used, and disclosed for business purposes the categories of personal information described in Section 2 (identifiers, customer records, commercial information, financial information, internet/network activity, geolocation, employment-related information, and sensitive personal information).
We retain each category for the period described in Section 7.
9.2 Sale and Sharing
We do not sell personal information for monetary consideration, and we do not share personal information for cross-context behavioral advertising. We have not sold or shared the personal information of consumers under 16 years of age.
9.3 Your Rights
Subject to verification and applicable exceptions, California residents have the right to:
- Know the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collecting or sharing personal information, and the categories of third parties to whom we disclose personal information.
- Delete personal information we have collected from you, subject to legal exceptions.
- Correct inaccurate personal information we maintain about you.
- Opt out of the sale or sharing of personal information (we do not engage in either).
- Limit the use and disclosure of sensitive personal information.
- Be free from retaliation for exercising any of these rights.
9.4 How to Exercise Your Rights
You may submit a request to know, delete, correct, or limit by emailing us at pod@flycraft.com, calling us at (310) 848-3636, or writing to us at the address in Section 15. We will verify your identity before responding. You may also designate an authorized agent to make a request on your behalf.
10.Other U.S. State Privacy Rights
Residents of other U.S. states with comprehensive privacy laws may have rights similar to those described in Section 9, including rights to access, correct, delete, port, and opt out of targeted advertising and certain profiling. To exercise any such right, please contact us using the methods in Section 9.4.
11.Privacy Rights of Residents of Other Countries
We are based in the United States, and personal information we collect will be transferred to and processed in the United States and other countries that may have data-protection laws different from those in your country. Where required, we use appropriate safeguards (such as the European Commission’s Standard Contractual Clauses and the U.K. International Data Transfer Addendum) to protect personal information transferred internationally. We will treat all information covered by this Policy in accordance with US federal and state laws and the terms of this Policy.
12.Children’s Privacy
Our Site 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 you believe a child has provided personal information to us, please contact us at pod@flycraft.com and we will take appropriate steps to delete the information.
13.Third-Party Sites and Services
Our Site may contain links to third-party websites and services that are not operated by the Glidepath Companies. We are not responsible for the privacy practices of those third parties, and this Policy does not apply to information collected by them. We encourage you to review the privacy policies of any third-party site you visit.
14.Changes to This Policy
We may update this Policy from time to time. When we make material changes, we will notify you by posting the updated Policy on the Site, by email, or by other means as required by law. The “Effective Date” at the top of this Policy indicates when it was last revised.
15.Contact Us
You can contact us about this Privacy Policy by writing or emailing us at the address below: