Elios Capital

Privacy Policy

Effective Date: March 26, 2026

This Privacy Policy describes how Elios Capital ("we," "our," or "us") collects, uses, stores, and discloses information about you when you visit our website (elioscapital.com), interact with our content on social media platforms including X (Twitter) and TikTok, subscribe to our communications, or otherwise engage with us (collectively, the "Services"). By using our Services, you agree to the practices described in this Policy. If you do not agree, please discontinue use of our Services.

This Policy applies to all visitors, subscribers, and users of our Services globally. We are committed to protecting your personal information and your right to privacy.

1. Information We Collect

1.1 Information You Provide Directly

We collect information you voluntarily provide when you:

• Subscribe to our email newsletter or mailing list (name, email address)

• Contact us via email, contact forms, or social media

• Register for or interact with third-party platforms we use (such as Dub.co)

• Respond to surveys, promotions, or other communications

1.2 Information Collected Automatically

When you visit our website, we and our third-party service providers may automatically collect:

• IP address and approximate geographic location (country/region level)

• Browser type, device type, and operating system

• Pages visited, time spent on pages, referring URLs, and click-through data

• Cookie identifiers and similar tracking technologies

• Log data and usage statistics

1.3 Payment and Subscription Information

We offer paid subscription services. All payment transactions are processed by third-party payment processors — currently Stripe, Inc. and Squarespace Payments. We do not collect, store, or have access to your full credit card number, CVV, or bank account details. These are entered directly into and handled exclusively by Stripe or Squarespace, which are PCI-DSS compliant processors.

We may receive and retain limited non-sensitive billing information from these processors, including:

• Your name and billing address as provided during checkout

• The last four digits of your card and card type (for reference purposes only)

• Subscription status, plan type, and renewal dates

• Transaction IDs and purchase history

By subscribing to our Services, you agree to the privacy policies and terms of Stripe (stripe.com/privacy) and Squarespace (squarespace.com/privacy) in addition to this Policy. We encourage you to review those policies directly.

1.4 Information from Third-Party Platforms

We may receive limited information from third-party platforms you use in connection with our Services, including:

• Social media platforms (X/Twitter, TikTok) when you follow, like, share, or interact with our content — subject to those platforms' own privacy policies

• Dub.co, the copy-investing platform through which our model portfolios are published

• Analytics providers (such as Google Analytics) that aggregate usage data across our site

• Email service providers that track opens, clicks, and delivery metrics

2. How We Use Your Information

We use the information we collect for the following purposes:

• To send you our newsletter, market commentary, portfolio updates, and promotional communications (with your consent)

• To operate, maintain, and improve our website and Services

• To respond to your inquiries and provide customer support

• To analyze how our Services are used and measure the effectiveness of our content

• To comply with applicable legal obligations

• To detect, investigate, and prevent fraudulent or unauthorized activity

• To personalize your experience where applicable

We do not use your personal information to make automated decisions that produce legal or similarly significant effects about you.

3. Legal Basis for Processing (GDPR / UK GDPR)

If you are located in the European Economic Area (EEA) or United Kingdom, we process your personal data under the following legal bases:

• Consent: Where you have opted in to receive marketing communications or allowed cookies

• Legitimate Interests: To operate our business, improve our Services, and prevent fraud — where such interests are not overridden by your rights

• Legal Obligation: Where processing is required by applicable law

• Contract Performance: Where processing is necessary to fulfill a service you have requested

You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

4. Cookies and Tracking Technologies

4.1 Types of Cookies We Use

We use the following types of cookies and similar tracking technologies:

• Essential Cookies: Necessary for the basic operation of our website. Cannot be disabled.

• Analytics Cookies: Help us understand how visitors interact with our website (e.g., Google Analytics). These cookies are only set with your consent where required.

• Marketing / Preference Cookies: May be set by embedded third-party content or platforms. Subject to your consent preferences.

4.2 Your Cookie Choices

Depending on your jurisdiction, you may be presented with a cookie consent banner allowing you to accept or decline non-essential cookies. You can also control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of our Services.

For information on opting out of Google Analytics specifically, visit: https://tools.google.com/dlpage/gaoptout

5. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties. We may share your information only in the following limited circumstances:

• Service Providers: We share data with trusted vendors who help us operate our Services (e.g., email platforms, hosting providers, analytics tools). These parties are contractually bound to process data only as instructed.

• Third-Party Platforms: Content you engage with on X, TikTok, or Dub.co is governed by those platforms' own privacy policies. We do not control how those platforms handle your data.

• Legal Requirements: We may disclose information if required by law, subpoena, court order, or governmental authority, or to protect our legal rights.

• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. We will notify you of any such change.

• With Your Consent: We may share your information in other ways if you have given us explicit permission to do so.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required by law. Specifically:

• Email subscriber data is retained for as long as you remain subscribed. You may unsubscribe at any time.

• Subscription and billing records are retained for a minimum of 7 years to comply with financial recordkeeping obligations, even after cancellation.

• Website analytics data is retained in aggregated or anonymized form in accordance with the retention policies of our analytics providers.

• Communications and correspondence may be retained for up to 3 years for legal and operational purposes.

When information is no longer needed, we delete or anonymize it in a secure manner.

7. Your Rights and Choices

7.1 All Users

Regardless of your location, you have the right to:

• Unsubscribe from marketing emails at any time by clicking "unsubscribe" in any email or contacting us directly

• Request access to the personal information we hold about you

• Request correction of inaccurate information

• Request deletion of your personal information, subject to legal retention obligations

7.2 EEA and UK Residents (GDPR / UK GDPR)

If you are in the EEA or UK, you additionally have the right to:

• Data portability: Receive your data in a structured, machine-readable format

• Restrict processing: Object to or restrict how we process your data in certain circumstances

• Object to processing: Object to processing based on legitimate interests or for direct marketing purposes

• Lodge a complaint with your local supervisory authority (e.g., the ICO in the UK, or your national data protection authority in the EU)

7.3 California Residents (CCPA / CPRA)

If you are a California resident, you have the right to:

• Know what categories of personal information we collect and how it is used

• Access your personal information

• Delete your personal information (subject to certain exceptions)

• Correct inaccurate personal information

• Opt out of the sale or sharing of personal information — we do not sell or share personal information as defined under CCPA

• Non-discrimination: We will not discriminate against you for exercising your privacy rights

To exercise any of these rights, please contact us using the information in Section 11. We will verify your identity before processing your request and respond within the timeframes required by applicable law.

8. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a child under 18, please contact us immediately at legal@elioscapital.com and we will promptly delete such information.

9. International Data Transfers

Our Services are operated from the United States. If you access our Services from outside the United States, please be aware that your information may be transferred to and processed in the United States or other countries, which may have different data protection standards than your home country.

For transfers from the EEA or UK to countries not deemed adequate by the European Commission or UK authorities, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent mechanisms to ensure your data is protected in accordance with applicable law.

10. Security

We take reasonable and appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include using secure servers, encrypted connections (HTTPS), and access controls.

For payment data specifically, we rely on Stripe and Squarespace — both PCI-DSS Level 1 certified processors — to handle all cardholder data. We do not transmit or store raw payment credentials on our own servers.

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security. You use our Services at your own risk.

11. Important Disclosures

11.1 Not Financial Advice

Elios Capital publishes content for informational and educational purposes only. Nothing on our website, social media channels, newsletters, or any other communication constitutes financial advice, investment advice, trading advice, or any recommendation to buy, sell, or hold any security. Past performance is not indicative of future results. All investing involves risk, including the possible loss of principal. You should consult a licensed financial advisor before making any investment decisions.

11.2 Third-Party Links and Platforms

Our Services may contain links to third-party websites, including Dub.co, X, TikTok, and others. We are not responsible for the privacy practices of those platforms. We encourage you to review the privacy policies of any third-party platforms you use.

11.3 No Attorney-Client Relationship

This Privacy Policy does not create an attorney-client relationship or any other professional relationship between you and us.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the Effective Date at the top of this page and, where required by law, notify you by email or by posting a prominent notice on our website. We encourage you to review this Policy periodically.

Your continued use of our Services after any changes constitutes your acceptance of the updated Policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Elios Capital

Email: legal@elioscapital.com

Website: elioscapital.com

We will respond to all legitimate requests within 30 days, or within any shorter period required by applicable law.