Privacy Policy

Last Updated: December 12, 2023



1. Introduction

Your experience using our service is very important to us. That’s why we want to do our best to ensure the information you provide us is protected. Our Privacy Policy (“Policy”) describes how Adelphi Stock Brokers Inc. and its affiliates (collectively, “Adelphi,” “we,” “our,” or “us”) collect, secure, use, protect, and share your personal information through our websites, mobile apps, and other online services including your interactions with us (collectively, the “Services”). This Policy will help you understand the following:



2. What Information We Collect

We collect information you provide when using our Service, engaging, or communicating with us. This collection includes:

  • Personal data such as full name, date of birth, government-issued identification documents (e.g., social security, passport), biometric identifiers, and other data on official identification documents.
  • Contact data such as mailing address, telephone number, email address.
  • Financial data such as bank account and payment card details, account balances, personal income, credit history, credit scores, tax information, and financial transaction history.
  • Profile data such as your username and password, your interests, age, preferences, feedback, and survey responses.
  • Additional data you provide such as customer support, surveys, and other content or information that you generate, transmit, or otherwise make available.

We also collect certain information about you automatically when you are using our Services. This includes:

  • Geolocation data which may include, city, state, and country and location associated with your Internet Protocol (IP) address. We may also collect GPS location of your mobile device in accordance with your device permissions. We only collect this information with your consent.
  • Activity data such as your transaction amount, type of transaction, time and date.
  • Preferences such as your preferences for receiving our marketing communications and privacy choices.
  • Usage information such as account log in, your activity on our Services, which includes device identifiers (like IP address, mobile device identifiers or Media Access Control (MAC), features you use, pages you visit, time and date of access and other similar usage information.
  • Cookies which are small text files that are stored onto user devices by websites when you browse the internet. It allows web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies of our third-party business partners and service providers.
  • Logical storage technologies like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
  • Web beacons also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.


Lastly, we may receive information about you from third parties. This includes:
  • Data providers, vendors, and business partners such as identity verification and fraud prevention partners, payment processing, credit records, service and data licensors.
  • Financial Account Linking Adelphi uses Plaid Inc. (“Plaid”) to link financial accounts and aggregate services. By utilizing these services, you acknowledge and agree that the terms of Plaid’s Privacy Policy (currently located at https://plaid.com/legal/#end-user-privacy-policy) which governs Plaid’s use of such information, and you consent to Plaid’s Privacy Policy. Furthermore, you grant Plaid the right, power, and authority to access and transmit your information as reasonably necessary for Plaid to provide its services.
  • Publicly available data via public records, social media platforms, government agencies, and other publicly available sources/sites.
  • Connected services such as when you log on to your Adelphi account through social media, Google, or Apple.


3. How We Use Your Information

The information we collect may be used for the following purposes:

• Provide our services to you, including responding to your inquiries, providing customer support, and processing transactions.
• Improve our services, including analyzing usage data, monitoring user feedback, and conducting research.
• Personalize your experience, including providing customized content, promotions, and recommendations.
• Communicate with you, including sending you updates, news, and other information about our products, services and new offerings, your financial accounts, and investments.
• Protect the safety and security of our Services, business, and customers.
• Comply with applicable laws and legal requirements.
• Protect or exercise our legal rights or defend against legal claims.


4. How We Share Your Information

We may share your information with third-party service providers who help us deliver our services, such as payment processors, data storage providers, and marketing partners. We may also share your information with third parties in the following circumstances:


  • Legal Compliance: We may disclose your information if required by law (legal or regulatory), court order, or other legal or regulatory process.
  • Business Transactions: We may disclose your information in connection with a merger, acquisition, or sale of our company or assets.
  • Consent: We may disclose your information if you have given us explicit consent to do so.

We require all third-party service providers to maintain the confidentiality and security of your information and to use your information only to provide services to us. We do not sell or rent your information to third parties for marketing purposes. However, we cannot control the actions of third-party service providers or guarantee that they will follow our privacy policies. We encourage you to review the privacy policies of these providers before providing them with your information.

Our services may contain links to third-party websites or services. We are not responsible for the privacy practices or the content of these third-party sites. We encourage you to review the privacy policies and terms of use of these sites before providing them with your information. We may aggregate or otherwise anonymize your personal information so that it does not reasonably identify you and share such information with third parties. We may provide your name, address, email address, and securities positions to requesting companies in which you hold securities. Where appropriate, we share information about you with other companies owned or controlled by Adelphi. These companies will process any information shared in the same manner as described under this Privacy Policy.
We may share information about you in connection with a substantial corporate transaction, a merger, consolidation, reorganization, financing, change in control or acquisition of all or a portion of our business by a third party, or in the unlikely event of a bankruptcy or similar proceeding. We disclose information about you if we believe that disclosure is in accordance with, or required by, any applicable law or legal process or to protect and defend the rights, interests, safety, and security of Adelphi, our users, or the public.
We share information about you for any other purposes disclosed to you with your consent.



5. Tracking, Analytics, Advertising

We may use cookies, web beacons, and other similar technologies to collect information about your usage of our website or services. This may include information about the pages you visit, the links you click, and the actions you take while using our website or services.

We may use this information to analyze user behavior and preferences, and to improve the quality and relevance of our services. We may also use third-party services, such as Google Analytics, to assist us in collecting and analyzing this data.
In addition, we may use third-party advertising networks to serve ads on our website or services. These networks may use cookies, web beacons, and other similar technologies to collect information about your activities on our website or services and other websites or online services in order to provide you with targeted advertising based on your interests.
If you do not wish to have this information collected or used for advertising purposes, you may opt out of such advertising by adjusting your browser settings or using third-party tools designed to block tracking cookies and similar technologies.
Please note that even if you opt out of targeted advertising, you may still see advertisements on our website or services, but they may not be as relevant to your interests.



6. Protecting Your Information

Adelphi understands the importance of safeguarding your personal information and is committed to protecting your privacy. We use various measures to manage and protect the personal information we collect from you.

At Adelphi, we have implemented reasonable security measures that are widely accepted by the industry. These measures are in place to safeguard information under our control from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. To ensure the protection of personal information, we maintain the appropriate physical, electronic and procedural safeguards. Access to personal information is granted only to those who need it for operational and regulatory purposes, and we strictly control the amount and type of information that can be downloaded or transmitted.
As a part of our ongoing efforts to maintain a secure system, we conduct regular audits to ensure the effectiveness of our system. However, we want to emphasize that no security system is impenetrable. Despite our best efforts, it is possible for hackers to gain illegal access to information, and our database and/or systems may be vulnerable to cyber-attacks. We want you to be aware of this fact and understand that we cannot guarantee absolute protection against such risks.
We hold onto your personal information until it serves the purpose for which it was originally collected and to fulfill our legal and regulatory obligations, including adhering to our record-keeping policies, and as permitted by our legitimate interests.



7. Managing Your Information

You have the right to access and update your personal information at any time. Adelphi users can manage their information in the following ways:

  • Account profile, you can access or update your personal information by logging into your account and going to the “my profile” section of the site.
  • Communication preferences, registered users can stop receiving promotional emails by clicking the unsubscribe button link in the email. We may still send you service-related or other non-promotional communications, such as account notifications, receipts, security notices and other transactional or relationship messages.
  • Limiting data sharing, we provide you with the option to control how we share your data with our marketing partners, so that we can optimize our efforts to promote our Services to you across various sites and applications. Users can disable this feature and Adelphi will no longer share your personal information with these partners for such purposes.
  • Cookies, are accepted by most web browsers and other tracking technologies by default. You have the option to configure your browser to delete or reject these technologies based on your preference. Please note that choosing to delete or reject these technologies may impact certain features of our Services. The opt-out process may need to be repeated if you switch to a different device, use a different browser, or delete the opt-out cookies that store your preferences.


8. California Residents

If you are a California resident, you have certain rights regarding your personal information under the CCPA.

Right to know: You have the right to request certain information: (1) the categories and/or specific pieces of personal information we have collected about you, (2) the categories of sources for that personal information, (3) the purposes for which we use that information, (4) the categories of third parties with whom we disclose the information, and (5) the categories of information that we sell or disclose to third parties. You can make a request to know up to twice a year, free of charge.

Right to delete: You can request we delete personal information we collected from you and tell our service providers to do the same, subject to certain exceptions (such as if we are legally required to keep the information).

Right to opt-out of sale or sharing: You may request we stop selling or sharing your personal information (“opt-out”), including via a user-enabled global privacy control. We cannot sell or share your personal information after we receive your opt-out request unless you later authorize them to do so again.

Right to correct: You may ask us to correct inaccurate information that we have about you.

Right to limit use and disclosure of sensitive personal information: You can direct us to only use your sensitive personal information (for example, your social security number, financial account information, your precise geolocation data, or your genetic data) for limited purposes, such as providing you with the Services you requested. You also have the right to be notified, before or at the point we collect your personal information, of the types of personal information we are collecting and what we may do with that information. We will not discriminate against you for exercising your rights under the CCPA. We cannot make you waive these rights, and any contract provision that says you waive these rights is unenforceable.



9. Children

We do not intentionally collect or request any information from individuals under the age of 13. If we become aware that we have unintentionally collected personal information from a child under the age of 13, we will take appropriate measures to delete that information. If you believe that we have information from a child under the age of 13 please contact us at privacy@adelphis.co.



10. Transfers

If our business is sold, merged, or otherwise transferred to another entity, your personal information may be transferred as part of that transaction. If such a transfer occurs, we will take steps to ensure that your information is protected, and that the new entity agrees to abide by this privacy policy.
We may also transfer your personal information to a third party in the event of an insolvency, bankruptcy, or receivership. In such cases, we will make reasonable efforts to ensure that your information is protected and used only for the purposes for which it was collected.



11. Changes to the Policy

We may change or update this Privacy Policy periodically. When we do, we will revise the “Last Updated” above and, in some cases, we provide additional notice by either adding a statement on our website or by sending you a notification. Any changes to this Policy will become effective when posted unless indicated otherwise.



12. How to Contact Us

If you have any questions about this Privacy Policy, please contact us at privacy@adelphis.co

Private Placement Risk Disclosures:

Private placements offerings have extensive risks and are speculative in nature. Therefore, it is important that anyone considering participating in a private placement offering understand the risks associated with such offering, including the possible loss of all funds invested. Specific risk factors for a private placement will be stated in its private placement memorandum. It is important that anyone considering investing in a private placement fully review and understand the risks associated with such offering.

Individuals considering private placement offerings should consult appropriate legal or other professional advice prior to making investment decisions.

Anything contained on this website should not be considered an offer to sell securities. The information contained herein is for informational purposes only. Only a formal, privately distributed offering memorandum and appropriate securities documents, fully executed by an accredited investor, will represent a sale of investment.

Note: The content of this website is provided for general information only to the public and shall not be construed as legal, financial, or securities advice on any subject matter.

See our Terms of Service for more information.

Adelphi Stock Brokers Inc., is a member of SIPC, which protects your brokerage account up to $500,000, including up to $250,000 in cash.

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