Privacy Policy

At RibaX Capital Limited Liability Company (“RibaX Capital”), our most valuable asset is the relationship we have with our clients. We honor and serve this relationship by maintaining the highest standard of trust and confidence, which includes safeguarding client information. Federal law gives our clients the right to limit some, but not all, sharing of their personal information. Unless an investment advisor is permitted or required by law to disclose client information to nonaffiliated third parties, clients must be given the opportunity to opt out of or prevent such disclosure.

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RibaX Capital Commitment to Privacy

Our clients’ privacy is not for sale. Neither RibaX Capital nor any of our affiliates (collectively, “RibaX Capital,” “we,” “our,” or “us”) sells nonpublic personal client information to anyone, for any reason, at any time. Only as permitted or required by law will RibaX Capital disclose client information to nonaffiliated third parties.

At RibaX Capital, we hold the confidence and trust placed in us by our clients in the highest regard. RibaX Capital has taken extraordinary measures to:

• Ensure continuous confidentiality of all client data, including biographical, professional, and financial information

• Ensure the physical and electronic security of all client records

• Protect against any anticipated threat to the security of such records

• Protect against any unauthorized access to such records

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Personal Information We Collect

In order to provide one or more of our investment advisory services, we collect clients’ personal information, which may include:

• Contact Information

  • Full legal name

  • Email address

  • Mailing address and physical address (if different)

  • Preferred phone number

• Identification Data

  • Social Security Number or Tax Identification Number

  • State or local identification card number

  • Date of birth

• Profile Information

  • Login credentials to establish access to our client portal

  • Investment risk tolerance, preferences, and objectives

  • Biographical details (e.g., education, employer)

  • Interests (e.g., boating, skiing, traveling)

  • Login credentials to review other accounts, if permitted by clientFamily member data provided by client (e.g., family members’ name, gender, age, and date of birth)​

• Financial Data

  • Income

  • Tax returns

  • Financial account and payment details provided by client

  • Investment holdings

  • Account balances and contributions

• Marketing Data

  • Preferences regarding communication about our services, events, and publications

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RibaX Capital may receive additional information about clients from other sources, such as:

• Vendors who assist us in providing clients with our advisory services

• Data providers who may share information about clients’ demographics, interests, and preferences

• Social media platforms

• Public records

• Business partners, such as our solicitors, custodians, or event cosponsors

• Our website, which provides information about pages or screens visitors have viewed, any actions taken (e.g., clicks and data entered) while visiting these pages or screens, and the duration of such access; browser type and IP address; and geographic location

• Existing RibaX Capital clients who may refer potential clients to us (please do not refer someone to us if they do not consent to their information being shared)

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Should a client prefer that RibaX Capital not share their personal nonpublic information with our nonaffiliated business partners, the client must contact their Wealth Management Team to state that preference. For any client whose primary state of residence (of record) is California or Vermont, RibaX Capital will not share such information with our nonaffiliated business partners unless the client “opts in” or affirmatively provides consent to do so. However, when a client signs an advisory agreement with RibaX Capital, the client is, in effect, asserting affirmative consent.

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How We Use Client Information

To provide clients with the investment advisory services under their advisory agreement, it is necessary for RibaX Capital to share client information within the firm and with nonaffiliated companies with which RibaX Capital has entered into an agreement in order to provide our services and/or products. It is our practice, however, to enter into written agreements with service providers imposing data-protection obligations no less protective than our own.

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How We Protect Your Information

RibaX Capital employs technical, organizational, and physical safeguards designed to protect the personal information we collect, including but not limited to:

• Storing hard copies of client records in a secured room and/or in an alarmed and locked building

• Revoking employees’ access to proprietary data upon termination of employment

• Delivering sensitive information to clients via secure channels (e.g., encrypted email, securely shared folder, client portal)

• However, security risk is inherent in all internet and information technologies. We cannot guarantee the security of a client’s personal information if the client provides us with such information via an unsecure channel.

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RibaX Capital will provide each client with an initial notice of the current privacy policy when the client relationship is established. RibaX Capital may amend this policy at any time. Clients will be provided with a copy of the updated privacy policy when material changes to the policy are made. If you have any questions about this privacy policy, please email us at info@ribaxcapital.com.