Updated: Feb. 7, 2025

This Privacy Policy outlines how we collect, use, and protect the information you provide when visiting our website elmfunds.com (the "Site").

Elm Partners Management LLC (“Elm Partners”) is committed to safeguarding the use of your personal information that we hold. Elm Partners (also referred to as “we”, “our” and “us” throughout this notice) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with our communications with you.

Elm Partners does not sell or transfer your personal data or information to anyone.

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Privacy Policy.

What information do we collect from you?‍

Only when we have a valid, legal reason to do so, we collect personal information that you voluntarily provide to us when you interact with the Site, including but not limited to:

• Personal Identification Information: Name, location (by region), email address, phone number, or other personal identifiers.
• Additional Investor Information: Information related to your account that you choose to share, such as investable assets, resident status, and investment preferences
• Website Usage Data: Data regarding your use of our Site, including IP addresses, browser types, operating systems, and cookies.
• Technology Data: Device data, log and usage data related to services, diagnostics, and performance. 

When do we collect this information?

• Research subscriptions
• Information requests
• Message form submissions
• Contact Forms

How long do we keep information?

Information is retained for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

How do we use your information?

We use the information we collect for the following purposes:

• To provide you with services related to the Fund
• To improve our website, services, and user experience through analytics and data analysis.
• Security and fraud prevention
• To comply with applicable laws, regulatory requirements, and obligations
• To communicate with you, including responding to inquiries, providing customer support, and marketing our services (with your consent).:
  
  • – Email updates, including recent posts to Elm’s blog and research notes
  • – Delivering information requests
  • – Materials related to Elm Partners and its services
• Email transcripts:
  
  • Our Customer Relationship Manager (CRM) software compiles a transcript of email interactions between Elm Partners and its users.

When and Who has access to this information?

• Elm Partners and its employees
• Service Providers: 
  
  • We may share your data with trusted third-party service providers who assist us in providing financial services, such as data storage, website hosting, or transaction processing. These service providers are required to protect your personal information and comply with relevant regulations.
• Third Party Applications and Services:
  
  • Elm Partners uses third-party applications and services that have access to customer data. This includes the Hubspot CRM toolset, as well as email clients such as Outlook and Gmail.
• Regulatory Authorities: 
  
  • We may disclose your information to regulators, such as the SEC, or other government authorities, as required to legally comply with securities regulations, legal obligations, or requests for information.
• Legal and Safety Purposes: 
  
  • We may disclose your information if required to do so by law or if we believe such action is necessary to comply with legal processes, protect our rights, or protect the safety of our users or the public.
    

How do we protect your information?

We take the security of your personal information seriously and implement reasonable physical, administrative, and technical safeguards to protect it. While no data transmission or storage system can be 100% secure, we use industry-standard encryption methods (e.g., SSL/TLS) to help protect your sensitive data during required transmission.

We require third parties that assist in providing our services to you to protect the personal information they receive. This includes contractual language in our third party agreements.

Our employees are also advised about Elm Partners’ need to respect the confidentiality of each client’s non-public and personal information. We train our employees on their responsibilities, and limit employee access to information as appropriate. We will share your personal information with third parties only with your express consent, except as otherwise outlined in this policy. 

In the event we discover a security breach, you will be notified within 72 hours of the discovery.

‍How can you control your information?

At any time, you can amend, update or correct your information by submitting a form through our website.

If you’d like to receive a copy of the information that we have, or request that we delete all of your personal data that we hold, please send a request to info@elmfunds.com.

Changes to our Privacy Policy

Periodically, we may revise our Privacy Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy.

Questions?

You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy, by contacting us at info@elmfunds.com.

For those who wish to receive a copy of their information, please send an email to info@elmfunds.com with “[Your Name] Information Request” in the Subject heading.

For those who wish to have Elm Partners delete the personal data that we hold, please send an email to info@elmfunds.com with “[Your Name] Delete my Information” in the Subject heading.

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For more information on the site cookies that we set, along with third-party cookies, please see our Cookie Policy here.