Privacy Policy

LEGAL PLACEHOLDER. This language is draft counsel text for a demonstration product of Vital Investment Management, LLC. It is not legal advice, is not an opinion of counsel, and is not in force until the firm's CCO and named counsel adopt it.

Vital Investment Management, LLC collects the information you submit so it can qualify and, if appropriate, introduce you through its own supervised intake. We do not sell your information to a marketplace of many firms. Measurement cookies, if ever configured, stay off until you allow them.

This policy covers information processed by Vital Investment Management, LLC when you use Vital Introductions, including the public site, the questionnaire, educational tools, measurement tags (if configured), and the waitlist. Advisor and admin portals are internal demonstrations and are not tagged for advertising.

Vital Introductions is not a consumer reporting agency. Qualification is not a credit decision and is not a consumer report.

Identifiers: name is optional in notes; email; phone if you provide it; IP address and approximate location if your browser sends them; campaign identifiers such as UTM parameters, gclid, gbraid, and wbraid.

Household financial information you self-report: investable-asset band, income band, specialties, timeline, whether you already have an advisor, household stage, meeting preference, city, and state.

Consent records: timestamps for email consent, SMS consent, and disclosure acknowledgment, plus measurement-cookie choice if tags are configured.

Qualification and routing records: money-gate result, score, reason codes, assigned advisor, decline events, and stubbed outbound messages.

We do not ask for Social Security numbers, account numbers, or full net-worth statements. Do not paste those into the notes field.

To apply the money gate and geography rules, to score a request, and to make at most one exclusive introduction (or one fallback if the first advisor declines within 15 minutes).

To email you about this specific request, and to send optional platform notices only if you check email consent.

To store SMS consent if you check it. This draft does not send SMS.

To supervise the service, debug, and defend legal claims.

To measure site use and advertising performance only if a measurement ID is configured and you allow measurement cookies.

Supervised persons of Vital Investment Management, LLC: if we make an introduction, we share your questionnaire answers and contact details with that one person. If that person declines within the exclusive window, we may share the same package with one additional supervised person. We do not sell the same household to a marketplace of many firms.

Service operators: in this draft, data stays on the local database used to run the demonstration. A later production host, email vendor, or cloud provider would be a processor under a written agreement.

Legal process: we may disclose information if required by law, to protect rights or safety, or in a business transfer of this demonstration, subject to this policy.

We do not sell personal information for money. If Google Ads or similar tags are later enabled, some California laws may treat advertising cookies as a share or a sale. That sharing stays off until you allow measurement cookies. You can decline. See the Cookie Notice and the Do Not Share section below.

Introduction requests, consent timestamps, and routing history are kept for supervision and to honor opt-outs. This draft does not yet implement an automated deletion schedule. Counsel should set a retention calendar before launch (for example, request files for a defined period, and consent records for as long as needed to prove consent).

If you ask us to delete your file, we will honor that request except where we must keep a record of the request, a legal hold, or a consent or opt-out log.

This draft uses a local password gate on advisor and admin pages and stores data in a local database. It is not a production control environment. Do not submit real client files or production secrets.

No method of transmission or storage is perfectly secure. If a later production incident occurs, we will notify affected people as applicable law requires.

Depending on your U.S. state, you may have the right to know, access, correct, delete, or obtain a portable copy of personal information, and to opt out of sale, sharing for cross-context advertising, or targeted advertising.

To make a request, email [email protected] with the subject line Privacy request and enough detail for us to find your file (usually the email used on the questionnaire). We will not require you to create an account. We may need to verify the request. An authorized agent may submit a request with proof of authority.

We will not deny the introduction service, charge a different price, or provide a different level of service because you exercised a privacy right, except as permitted if the difference is reasonably related to the value of the data.

We honor a browser Global Privacy Control signal as an opt-out of sale or share for measurement cookies when those tags are configured. Email and SMS consent are separate from measurement cookies.

We collect the categories listed above for the purposes listed above. We retain them as described under Retention. We do not collect sensitive personal information as that term is used in the CPRA (such as government ID, precise geolocation, or account logins) in the questionnaire. Do not provide those items.

We do not use or disclose sensitive personal information for purposes that require a separate CPRA limit-use right in this draft.

California residents may designate an authorized agent and may appeal a denial by replying to our decision email with the word Appeal.

The service is for adults. We do not knowingly collect information from anyone under 18. If you believe a minor submitted a request, contact [email protected] and we will delete it.

We do not offer the service outside the United States and the District of Columbia. Do not submit a request from another country. If we learn a request is international, we will not route it.

Privacy contact: [email protected] or (970) 776-3316. Controller: Vital Investment Management, LLC, 4045 St. Cloud Drive, Suite 220, Loveland, CO 80538.