Privacy Policy

The Company respects your privacy and is committed to protecting the personal information you provide when visiting our website or requesting access to our private client portal.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in connection with our website, account registration process, private portal, and related communications.

This Policy should be read together with our Terms & Conditions.

1. Information We Collect

We may collect the following categories of information, depending on how you interact with our website and services.

A. Information You Provide

When you contact us, request an account, or communicate with us, we may collect:

• Name and email address.

• Account registration details and login-related information.

• Information you provide when requesting access to the private portal.

• Communications, inquiries, and correspondence with the Company.

• Records of account approval, acceptance of our Terms & Conditions, and other account-related actions.

We seek to collect only information reasonably necessary for the purposes described in this Policy.

B. Information Collected Automatically

When you visit the website or use the private portal, we or our service providers may collect certain technical information, such as:

• Internet Protocol (IP) address.

• Browser type, operating system, and device information.

• Pages visited, access times, and website usage information.

• Authentication events, account activity, and security logs.

• Cookie identifiers and similar technical information, where applicable.

The information collected depends on the website configuration, hosting platform, authentication services, and any analytics or security tools in use.

C. Information We Do Not Intentionally Request

Unless expressly necessary for a separately established business relationship, we do not intend to collect sensitive personal information, government identification numbers, financial account credentials, or detailed personal financial information through the general website or account registration process.

Please do not submit such information through the website unless we have specifically requested it through an appropriate channel.

2. How We Use Personal Information

We may use personal information for the following purposes:

• Reviewing, approving, rejecting, and administering private portal access requests.

• Creating, authenticating, maintaining, and securing user accounts.

• Communicating with users concerning access, account administration, and inquiries.

• Providing authorized access to Company research, commentary, and other website materials.

• Enforcing our Terms & Conditions and protecting proprietary and confidential information.

• Detecting unauthorized access, fraud, misuse, security incidents, or violations of applicable terms.

• Maintaining website functionality, troubleshooting technical problems, and improving website performance.

• Complying with legal obligations and protecting the Company's legal rights.

• Establishing, exercising, or defending legal claims where necessary.

We will not use personal information for materially different purposes without providing additional notice or obtaining consent where required by applicable law.

3. Cookies and Similar Technologies

The website or its service providers may use cookies, local storage, pixels, or similar technologies to support website functionality, maintain sessions, authenticate users, protect account security, and understand website usage.

The specific technologies used depend on the website's configuration and third-party services.

You may be able to manage cookies through your browser settings. Disabling certain cookies may impair login, authentication, or other website functions.

Where required by applicable law, we will obtain consent before using nonessential cookies or similar technologies and will honor applicable opt-out requirements.

4. How We Share Personal Information

We do not disclose personal information indiscriminately. However, we may disclose information in the following circumstances:

A. Service Providers

We may share personal information with service providers that perform services on our behalf, such as website hosting, account authentication, email communications, security, analytics, and technical support.

These providers may process personal information only as permitted by applicable agreements and instructions, subject to applicable law.

B. Legal Obligations and Protection

We may disclose information when reasonably necessary to comply with applicable law, regulations, legal process, or lawful governmental requests, or to protect the rights, property, security, and legal interests of the Company, its users, or others.

C. Business Transactions

Personal information may be disclosed in connection with a proposed or completed merger, acquisition, financing, restructuring, sale of assets, or other business transaction, subject to appropriate confidentiality safeguards and applicable law.

D. With Your Consent

We may disclose information for other purposes when you direct us to do so or provide the required consent.

We do not sell personal information for monetary consideration or share personal information for cross-context behavioral advertising, unless this Policy is updated to disclose such practices and any required rights and choices are provided. This statement must be confirmed against the Company's actual practices before publication.

5. Confidentiality of Proprietary Research

The Company's proprietary investment research, trading methodologies, economic and geopolitical analysis, models, forecasts, and other restricted materials are subject to the confidentiality and use restrictions described in our Terms & Conditions.

This Privacy Policy addresses the handling of personal information. It does not replace or diminish the confidentiality obligations applicable to Company research or other proprietary information.

We take reasonable steps to restrict access to personal information and account data to authorized persons and service providers who require access for legitimate business purposes.

6. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, including account administration, security, recordkeeping, legal compliance, and dispute resolution.

Retention periods may vary depending on the nature of the information, whether an account remains active, applicable legal requirements, and legitimate business needs.

When personal information is no longer reasonably necessary, we will take appropriate steps to delete it, destroy it, or de-identify it, subject to applicable law and legitimate retention requirements.

Closing an account does not necessarily result in the immediate deletion of all associated records.

7. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, or misuse.

These measures may include access controls, authentication, restricted permissions, and appropriate security practices provided by our service providers.

No website, electronic transmission, or storage system can be guaranteed to be completely secure. We therefore cannot guarantee absolute security.

If a personal data breach occurs, we will take appropriate steps to investigate and respond, including providing notifications when required by applicable law.

8. Your Privacy Rights

Depending on your location, the nature of our activities, and applicable law, you may have rights concerning your personal information, including the right to:

• Request confirmation of whether we process your personal information.

• Request access to certain personal information.

• Request correction of inaccurate personal information.

• Request deletion of personal information, subject to applicable exceptions.

• Obtain a portable copy of certain personal information where required by law.

• Opt out of certain processing activities, including the sale of personal information, targeted advertising, or certain profiling, where applicable.

• Withdraw consent where processing is based on consent.

• Appeal a decision concerning a qualifying privacy request, where required by law.

These rights are subject to applicable legal conditions and exceptions. Not every right applies to every individual or every type of information.

How to Submit a Request

To submit a privacy request, contact us at:

Email: contact@mullionmanagement.com

Please identify the nature of your request and provide sufficient information for us to verify your identity and respond appropriately. We may request additional information where reasonably necessary to verify your identity or authority.

We will respond within the time periods required by applicable law. Where permitted, we may extend a response period or decline a request when a legal exception applies.

We will not unlawfully discriminate against you for exercising privacy rights available to you under applicable law.

9. Connecticut Privacy Law

Mullion Management is based in Connecticut and seeks to handle personal information responsibly and in accordance with applicable privacy and data protection laws.

The Connecticut Data Privacy Act and other applicable laws may provide certain individuals with rights concerning personal information, subject to statutory applicability requirements, exceptions, and limitations.

Where applicable law grants you privacy rights, you may exercise them using the contact information in this Policy. We will honor applicable requests and opt-out preference signals as required by law.

Nothing in this Policy is intended to waive, limit, or diminish any rights that cannot lawfully be waived or limited.

10. Third-Party Websites and Services

Our website may contain links to third-party websites or use third-party services for hosting, authentication, communications, or other functions.

Those third parties may maintain their own privacy policies and practices. We are not responsible for the independent privacy practices of third parties, except to the extent applicable law provides otherwise.

We encourage you to review the privacy policies of third-party services when appropriate.

11. Children's Privacy

Our website and private research portal are intended for adults and are not directed to children under the age of 13.

We do not knowingly collect personal information online from children under 13. If we become aware that we have collected such information without the required authorization, we will take appropriate steps to delete it or otherwise address the issue in accordance with applicable law.

12. Changes to This Privacy Policy

We may update this Policy from time to time to reflect changes in our business, website functionality, service providers, legal obligations, or privacy practices.

The revised Policy will be posted on this page with an updated effective date or last-updated date.

If we make material changes, we will provide additional notice or obtain consent where required by applicable law.

Your continued use of the website after an update does not override any consent or notice requirement imposed by applicable law.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our handling of personal information, please contact:

Mullion Management, LLC
Email: contact@mullionmanagement.com
Website: https://mullionmanagement.com