Effective June 21st, 2022
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.
The types of personal information we collect and share depend on the product or service you have with us. This information can include account balances, trading history, account transactions, and blockchain address information. When you are no longer our customer, we continue to share your information as described in this notice.
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 Shrimpy Advisory chooses to share; and whether you can limit this sharing.
Questions? Email firstname.lastname@example.org.
This privacy notice is provided by Benthos Labs Advisory, LLC dba Shrimpy Advisory.
How Does Shrimpy Advisory protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Shrimpy Advisory collect my personal information?
We collect your personal information, for example, when you provide account information or give us your contact information. We also collect your personal information from other companies.
Why can't I limit all sharing?
Federal law gives you the right to limit only:
• sharing for affiliates’ everyday business purposes
• affiliates from using your information to market to you
• sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.
Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include companies with a Shrimpy or Benthos Labs name.
Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates we share with can include direct marketing companies.
Joint Marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include financial service companies.
California: If your Shrimpy Advisory account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law.
Vermont: If your Shrimpy Advisory account has a Vermont mailing address, we will not share personal information we collect about you with non-affiliates unless the law allows, or you provide authorization.
Shrimpy Advisory stresses its privacy and security standards to guard against identity theft and provide security for your personal information. We regularly re-evaluate our privacy and security policies and adapt them as necessary to deal with new challenges.
Personal Information Collected
We collect the following personal information from you:
• contact information such as name, email address, jurisdiction;
• billing information such as credit card number, and billing address;
• financial information such as blockchain addresses and exchange API keys;
• unique identifiers such as username, account id, and password;
• preferences information such as product wish lists, order history, and marketing preferences;
• demographic information such as age, education, gender, interests, and zip code.
When you visit the Site or download and use our Services, we may automatically collect certain information sent to us by your computer, mobile device, or any other device. This information may include the type of device you use, operating system, the device identifier (or "UDID"), your IP address, location, mobile network information, and standard web log information, such as your browser type traffic to and from our site, the pages you accessed on our website, and other available information. We may also collect information about your use and interaction with the Site, our mobile application, or our Services. For example, we may evaluate your computer, mobile phone, or other access device to identify any malicious software or activity that may affect the availability of the Services. When you use the Services, we may also store information based on your usage history. This includes, but is not limited to, details of your purchases, content you viewed, event information, click stream information, and cookies that may uniquely identify your browser or your account.
Information Use and Sharing
Shrimpy Advisory uses and discloses your personal information only as follows:
• to deliver to you any administrative notices, money alerts, and communications relevant to your use of the Service;
• to fulfill your requests for certain products and services;
• for market research, project planning, troubleshooting problems, and detecting and protecting against error, fraud, or other criminal activity;
• to third-party contractors that provide services to Shrimpy Advisory and are bound by these same privacy restrictions;
• to analyze site usage and improve the Service;
In the event that you access the Service as brought to you by one of our co-brand partners, through a co-branded URL, your email address used for registration on the Service may be provided to that co-brand partner.
We may use information you provide to connect you with people you may already know. For example, through our mobile application we may identify contacts within your address book as potential new users of Shrimpy Advisory. We may match the contact information you provide to the information provided by other users to improve the Service, including making it easier to find contacts you may refer to Shrimpy Advisory that are not already customers.
We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
If Shrimpy Advisory is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Third Party Services
User Access and Choice
You may decline to provide Personal Information to Shrimpy. Declining to provide Personal Information may disqualify you from using Shrimpy Services, Site, and App features that require certain Personal Information.
If the personal information on file for you changes, or if you no longer desire our service, you may correct or update it by making the change on our customer information page or by emailing email@example.com.
We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.
If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at firstname.lastname@example.org.
Cookies / Tracking Technologies
We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory.
If you reject cookies, you may still use the Site, but your ability to use some areas of the Site, such as contests or surveys, may be limited.
We employ (and/or our third-party advertising partner employs) a software technology called clear gifs (sometimes known as web beacons or web bugs), that help us better manage content on the Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.
Notice Concerning Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. At this time, we do not recognize or respond to DNT signals.
The security of your personal information is important to us. When you enter sensitive information, such as a credit card number or financial information, on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Site, please contact us.
California Collection Notice
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)), other than the personal information we collect in connection with providing financial products and services.
Depending on how you interact with our website and services, we may collect the following categories of personal information about you, in addition to the information we collect in connection with providing financial products and services:
• Internet usage information, such as browsing history, access history, and use and interaction with our website.
• Identifiers, such as your name and contact information, IP address, and mobile device identifiers.
Your California Privacy Rights
If you are a California resident, you may have certain rights. California law may permit you to request that we:
• Provide access to and/or a copy of certain information we hold about you.
• Delete certain information we have about you.
• Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
You may have the right to receive information about the financial incentives that we offer to you for your personal information (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law.
If you ask us to delete certain information, you may no longer be able to access or use the Services.
California consumers may request, once per year, that we disclose the identity of any third parties with whom we have shared personal information for the third parties’ direct marketing purposes within the previous calendar year, along with the type of personal information disclosed.
To exercise your rights, please send us an email at email@example.com. You will need to provide additional information to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
Additional Information for California Residents
The CCPA sets forth certain obligations for businesses that “sell” personal information. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months. We do not sell information that directly identifies you such as your name and email address. We share certain information as set forth in the Information Use and Sharing section, above, and allow third parties to collect certain information about your activity, for example through cookies, as explained in Cookies / Tracking Technologies section, above. You can control these cookies through browser settings and other controls. We do not believe these activities are a sale of personal information.
3833 E Main Street
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The above material and content should not be considered to be a recommendation to invest in a basket or an individual digital asset. Investing in digital assets or cryptocurrency (collectively “digital assets”) is highly speculative and volatile, and digital assets are only suitable for investors who are willing to bear the risk of loss and experience sharp drawdowns.
Shrimpy Advisory is an investment adviser registered with the US Securities and Exchange Commission. Registration as an investment adviser does not imply a particular level of skill or training. Shrimpy Advisory exclusively provides investment advisory services related to investing in digital assets.
Shrimpy Advisory is not a broker-dealer, exchange, custodian, or wallet provider, and is not intended for frequent trading activity. The articles and client support materials available are educational only and not investment or tax advice.
Who Provides What Service?
Investment Advice: Advisory services for digital assets are provided by Shrimpy Advisory, an SEC-registered investment adviser.
Digital Asset Trading Services & Custody: Digital asset trading services and custody are provided by Gemini Trust Company, LLC. For further details regarding the custody of assets, including cash, held at Gemini Trust Company, please see your Gemini user agreement.
Risk: Investing involves risk and there is the potential of losing money when you invest in securities and digital assets. Past performance does not guarantee future results and the likelihood of investment outcomes are hypothetical in nature. Any past performance in the above material of digital assets do not represent the performance of a Shrimpy Advisory account and does not reflect the deduction of the Shrimpy Advisory fee. Regarding any instance of extracted performance, Shrimpy Advisory offers to provide promptly the performance of the total portfolio.
Investments in digital assets are: Not FDIC or SIPC Insured • Not Bank Guaranteed • May Lose Value
Before investing, consider your investment objectives and Shrimpy Advisory's fees and expenses. Shrimpy Advisory's internet-based advisory services are designed to assist clients in achieving discrete financial goals. They are not intended to provide comprehensive tax advice or financial planning with respect to every aspect of a client's financial situation and do not incorporate specific investments that clients hold elsewhere. For more details, see Shrimpy Advisory’s Form CRS, Form ADV Part 2A and other disclosures.
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