Our Online Privacy Policy

What personal information is collected?

Ponzio Capital only collects personal information on a voluntary basis. If you submit information to Ponzio Capital, it will usually take the form of either: (1) using one of our contact forms, or (2) calling, mailing, or otherwise contacting our offices. Personal information collected may include your name, home address, phone number, and/or e-mail address. We do not require this information to gain access to our site other than for access to certain sections that require registration with us, such as the private section of the Ponzio Investors Funds.

What other types of information may we collect?

Your web browser or client software may transmit certain geographic information or information non-personally identifiable information regarding your computer (capabilities, flash player version, etc.) to Ponzio Capital. Ponzio Capital may use this information to generate aggregate statistics about our visitors to enhance your experience on our website.

How do we use your personal information?

We use non-personally identifiable information for demographic and statistical purposes. Any personally identifiable information you provide to us shall be treated with the same respect and care received by our clients. To learn more about how we protect client information, read the section entitled "Offline Privacy" below.

Offline Privacy

Ponzio Capital does not rent, sell, pledge, loan, or otherwise give your personal or financial information to anyone except service providers that Ponzio Capital may employ to provide us in managing your account (e.g., Interactive Brokers LLC, Ponzio Investors Fund's auditor). Prior to providing and to the extent that we provide your personal information to these service providers, we will ensure that they maintain a policy of not sharing your personal financial information to outside parties.

Though we attempt to protect your personal and financial information to the maximum extent possible, we will provide any such information if requested by a court order and in accordance with applicable rules and regulations.

In connection with providing clients with investment management services, we may obtain information about them from the following sources: (i) client agreements, profiles, and other information that clients provide to us, whether in writing, in person, by telephone, electronically or by any other means (which information may include a client's name, address, phone number, e-mail address, social security number, employment information, income, investment experience, and credit references; (ii) personal tax returns provided by the client; (iii) transactions on a client's behalf (which information may include the client's account balances, positions, investment interests and history; and (iv) public sources.

We only disclose non-public client information to nonaffiliated third parties without prior client consent when we believe it necessary for the conduct of our business or as required or permitted by law, such as: (i) if you request or authorize the disclosure of the information; (ii) to provide client account services or account maintenance; (iii) to respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities; (iv) to perform services for Ponzio Capital or on its behalf to develop or maintain proprietary trading or other software; (v) in connection with a proposed or actual sale, merger, or transfer of all or a portion of our business or an operating unit; and, (vi) to help us prevent fraud.

We do not make any disclosure of client non-public personal information to other companies who may want to sell their products or services to you. For example, we do not sell client lists and we will not sell client names to catalogue companies.

What if I have a question or complaint?

If you have any questions or wish to file a complaint, please feel free to call us toll-free at (800) 240-2124, or send a letter addressed to Ponzio Capital Inc., PO Box 35026, Elmwood Park, Illinois 60707-5026.

By using this Website, you signify your assent to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use this site. This Privacy Policy may change from time to time without notice, so please check back periodically to ensure that you are aware of any changes. If we make a material change to this Privacy Policy, we will attempt to notify you by posting the change on this website or in this Privacy Policy and, if necessary, give you additional choices regarding such change. Your continued use of the Ponzio Capital website will signify your acceptance of these changes.

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