Last updated: October 2026

Financial Privacy Notice

Rev. October 2026

FACTS WHAT DOES EMANAY DO WITH YOUR PERSONAL INFORMATION?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on the service you have with us. This information can include: your Social Security number, name and address; financial and tax information; account balances and transaction history; investment objectives and experience; and immigration-related financial documents (such as source-of-funds records). When you are no longer our client, we continue to share your information as described in this notice.
How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, the reasons Emanay chooses to share, and whether you can limit this sharing.
Reasons we can share your personal information Does Emanay share? Can you limit this sharing?
For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No
For our marketing purposes — to offer our products and services to you Yes No
For joint marketing with other financial companies No We don’t share
For our affiliates’ everyday business purposes — information about your transactions and experiences (Emanay companies serving the same client) Yes No
For our affiliates’ everyday business purposes — information about your creditworthiness No We don’t share
For our affiliates to market to you No We don’t share
For nonaffiliates to market to you No We don’t share
Questions? Email legal@emanay.io or write to Emanay Inc., 1221 Brickell Avenue, Suite 900, Miami, Florida 33131.
Who we are
Who is providing this notice? Emanay Holdings LLC and its subsidiaries: Emanay Inc. (dba Emanay Advisors), Emanay Accounting, Emanay Capital, Emanay Technologies, Emanay Ventures and Emanay Realty.
What we do
How does Emanay protect my personal information? To protect your personal information from unauthorised access and use, we use security measures that comply with federal law. These include role-based access, separation of each client’s data, encryption in transit, multi-factor authentication, activity logging and confidentiality obligations for everyone who handles your information.
How does Emanay collect my personal information? We collect your personal information, for example, when you open an engagement or account, give us your income, tax or account information, provide identity or source-of-funds documents, or pay us. We also collect it from others, such as banks and financial companies you connect, identity-verification providers, and affiliates.
Why can’t I limit all sharing? Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes (information about your creditworthiness), affiliates from using your information to market to you, and sharing with nonaffiliates to market to you. State laws and individual companies may give you additional rights to limit sharing.
Definitions
Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include the Emanay Holdings companies listed above.
Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies. Emanay does not share with nonaffiliates so they can market to you.
Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Emanay does not jointly market.