Proflex Finance LLC (“Proflex,” “PFL,” “we,” “our,” or “us”) respects your privacy. This Website Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit ProflexFinance.com or interact with our related online services (collectively, the “Site”).
Proflex is a registered investment adviser (CRD #334262). The Site also provides access to investment research, newsletters, market commentary, model portfolios, webinars, events, communities, subscription services, and other research and educational content (“Research Services”).
This Website Privacy Policy applies primarily to Site visitors, prospective clients, newsletter subscribers, Research Service and All-Access subscribers, webinar and event participants, community members, and others who interact with Proflex online.
If you become an investment advisory client of Proflex, information collected in connection with that advisory relationship may also be governed by Proflex’s separate financial privacy notice, investment advisory agreement, and applicable financial privacy laws.
This Website Privacy Policy should be read together with our Terms of Service.
1. Information We Collect
The information we collect depends on how you interact with Proflex and the Site.
Information You Provide to Us
We may collect information you voluntarily provide, including:
- name;
- email address;
- telephone number;
- mailing address;
- information submitted through contact, inquiry, or registration forms;
- information provided when scheduling a consultation;
- newsletter and Research Service registration information;
- All-Access or other subscription information;
- webinar, event, or community registration information;
- account or login information, where applicable;
- payment or transaction-related information associated with paid services;
- information concerning investment interests, goals, or financial circumstances that you voluntarily provide when communicating with us; and
- communications, questions, feedback, or other information you provide to Proflex.
Payment information may be collected and processed by third-party payment processors rather than directly by Proflex. Information provided directly to those third parties is also subject to their applicable privacy policies and terms.
Please do not submit Social Security numbers, brokerage or bank account credentials, passwords, or other highly sensitive financial information through general Site contact forms, community channels, or unsecured email.
2. Information Collected Automatically
When you visit or interact with the Site, we and our service providers may automatically collect certain information, including:
- Internet Protocol (“IP”) address;
- browser and device type;
- operating system;
- pages viewed and links clicked;
- referring website or source;
- date, time, and duration of Site visits;
- approximate geographic location derived from an IP address;
- interactions with emails or other electronic communications;
- advertising or campaign attribution information; and
- other Site usage and technical information.
We may collect this information through cookies, pixels, tags, web beacons, software development tools, analytics technologies, and similar technologies.
3. How We Use Information
We may use personal information to:
- operate, maintain, secure, and improve the Site;
- respond to inquiries and requests;
- provide newsletters and Research Services;
- administer All-Access and other subscriptions;
- provide access to webinars, events, videos, communities, and related content;
- schedule consultations and communicate with prospective clients;
- administer accounts, registrations, subscriptions, and payments;
- provide requested services and communications;
- personalize or improve Site content and user experiences;
- understand how visitors use the Site and our communications;
- measure the effectiveness of marketing campaigns and advertising;
- communicate about Proflex products, services, research, events, or other offerings where permitted by law;
- prevent fraud, abuse, cybersecurity threats, or unauthorized activity;
- maintain legal, business, regulatory, compliance, tax, and audit records;
- enforce our Terms of Service and other agreements; and
- comply with applicable laws, regulations, regulatory inquiries, legal process, or governmental requests.
4. Research Services and Investment Advisory Services
The Site provides access to Research Services that may include newsletters, investment research, market commentary, model portfolios, trade ideas, alerts, webinars, live sessions, videos, and investor communities.
Information collected in connection with these services may be used to administer your subscription or participation, provide the applicable Research Service, communicate with you, and improve our offerings.
Use of the Site or subscription to a Research Service does not, by itself, create an individualized or discretionary portfolio-management relationship with Proflex. Individualized investment advisory services are provided pursuant to a separate written investment advisory agreement.
If you become an advisory client, personal and financial information collected in connection with that advisory relationship may be subject to Proflex’s separate financial privacy notice and other client disclosures.
5. Cookies, Analytics, and Similar Technologies
We and our service providers use cookies and similar technologies for purposes that may include:
- enabling Site functionality;
- maintaining preferences;
- remembering user interactions;
- measuring Site traffic and performance;
- understanding how visitors use the Site;
- measuring email and newsletter engagement;
- identifying the source of Site visits;
- measuring conversions and marketing campaigns;
- preventing fraudulent or unauthorized activity; and
- supporting advertising and remarketing activities.
These technologies may collect information about your browser, device, Site activity, and interactions with advertisements or communications.
You may be able to control or delete cookies through your browser settings. Blocking certain cookies may affect the operation or functionality of the Site.
6. Advertising and Measurement Technologies
Proflex may use third-party analytics, advertising, and measurement technologies to understand Site activity, measure advertising effectiveness, identify how visitors arrive at the Site, and present or measure advertising relating to Proflex services.
These technologies may permit third parties to collect information about your browser, device, or Site interactions over time and, depending on the technology involved, across websites or online services.
Proflex does not sell personal information for monetary consideration.
However, certain disclosures of information through advertising or measurement technologies may be considered a “sale,” “sharing,” or use for targeted or cross-context behavioral advertising under some state privacy laws even where no money is exchanged.
Where applicable law provides an opt-out right with respect to these activities, Proflex will provide and honor the required method for exercising that right.
7. Third-Party Service Providers
We may use third-party service providers to operate or support the Site and our services. These providers may include providers of:
- website hosting and infrastructure;
- analytics and performance measurement;
- customer relationship management;
- email and newsletter delivery;
- appointment scheduling;
- payment processing;
- advertising and campaign measurement;
- video hosting;
- webinars and virtual events;
- community, messaging, and communications services;
- cybersecurity and fraud prevention; and
- compliance, professional, and business services.
For example, the Site may use or link to third-party platforms for scheduling, payments, video content, messaging, or community access.
Where a third party processes personal information on our behalf, we expect it to use that information for the services it provides to us and subject to applicable contractual and legal requirements.
Information you provide directly to a third-party platform may also be governed by that third party’s own privacy policy and terms.
8. How We Disclose Personal Information
We may disclose personal information to:
- service providers and contractors supporting our operations;
- payment processors;
- website, hosting, analytics, CRM, email, and scheduling providers;
- advertising and measurement providers;
- webinar, video, communications, and community platforms;
- custodians or financial institutions where appropriate in connection with investment advisory services;
- professional advisers, including attorneys, accountants, auditors, consultants, and compliance providers;
- governmental agencies, regulators, courts, law-enforcement authorities, or other parties when required or permitted by law;
- parties where disclosure is reasonably necessary to investigate or prevent fraud, security incidents, unlawful activity, or violations of our agreements;
- parties involved in a proposed or completed merger, acquisition, financing, reorganization, sale of assets, or similar transaction; and
- other parties at your direction or with your consent.
We do not disclose advisory-client nonpublic personal information to unaffiliated third parties for their independent marketing purposes except as permitted by applicable law or as described in Proflex’s applicable financial privacy notice.
9. Email, Newsletter, and Marketing Communications
If you subscribe to a newsletter, Research Service, webinar, event, or other communication, we may use the contact information you provide to send the requested communications and related information about Proflex services.
You may unsubscribe from promotional or newsletter emails by using the unsubscribe link contained in the applicable email or by contacting us.
Certain transactional, account, legal, compliance, security, or service-related communications may not be subject to marketing opt-outs.
10. Investor Communities and Third-Party Platforms
Proflex may provide access to investor communities, messaging services, discussion groups, webinars, live sessions, or similar interactive services.
These services may be operated through third-party platforms. Information you post or otherwise make available to other participants may be visible to those participants and should not be considered private.
Please do not disclose confidential financial information, account credentials, Social Security numbers, or other sensitive personal information in community discussions or other public or semi-public areas.
Proflex is not responsible for the independent privacy practices of other community participants or third-party platforms.
11. Third-Party Links
The Site may contain links to websites or services operated by third parties.
This Website Privacy Policy does not govern the privacy practices of those third parties. We encourage you to review the privacy policy of any third-party website or service before providing personal information.
12. California and Other U.S. State Privacy Rights
Depending on your state of residence, applicable law, and Proflex’s obligations under that law, you may have rights concerning your personal information.
These rights may include the right to:
- request information concerning personal information we collect or maintain;
- access personal information;
- request deletion of personal information;
- request correction of inaccurate personal information;
- obtain a portable copy of certain personal information;
- opt out of certain sales or sharing of personal information;
- opt out of targeted or cross-context behavioral advertising;
- limit certain uses or disclosures of sensitive personal information where applicable; and
- exercise privacy rights without unlawful discrimination.
These rights are subject to applicable exemptions and limitations.
For example, certain information collected in connection with financial or investment advisory services may be governed by the Gramm-Leach-Bliley Act or other financial privacy laws and may be excluded from some state consumer privacy-law requirements.
To submit an applicable privacy request, contact us using the information listed under “Contact Us” below.
We may need to verify your identity before processing certain requests. Authorized agents may submit requests where permitted by applicable law, subject to appropriate verification.
California Opt-Out Rights
Proflex does not sell personal information for monetary consideration.
To the extent our use of advertising, analytics, or other technologies constitutes “selling” or “sharing” personal information under the California Consumer Privacy Act (“CCPA”), eligible California residents may exercise applicable opt-out rights through any privacy-choice mechanism made available on the Site or by contacting us.
Where required by applicable law, we also honor recognized opt-out preference signals, such as Global Privacy Control (“GPC”).
13. Do Not Track
Some browsers provide a “Do Not Track” (“DNT”) setting.
Because there is not currently a uniform industry standard governing DNT signals, the Site may not respond to traditional DNT signals.
This does not affect our obligation to recognize legally required opt-out preference signals, including GPC where applicable.
14. Data Security
We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, or disclosure.
Our safeguards are designed according to the nature and sensitivity of the information involved and may include access controls, security procedures, vendor oversight, employee practices, and technical protections.
No internet transmission, electronic storage system, or security measure can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of information transmitted to or maintained by us.
15. Data Retention
We retain personal information for as long as reasonably necessary for the purposes for which it was collected and for legitimate legal, regulatory, compliance, security, tax, accounting, or business purposes.
Retention periods may differ depending on:
- the type of information;
- the nature of your relationship with Proflex;
- the services involved;
- regulatory recordkeeping requirements;
- legal or contractual obligations; and
- security, fraud-prevention, or dispute-resolution needs.
When information is no longer reasonably required, we may delete, anonymize, or securely dispose of it in accordance with applicable law and our record-retention practices.
16. Children’s Privacy
The Site and Proflex services are intended for adults and are not directed to children.
We do not knowingly collect personal information online from children under 13.
We also do not knowingly sell or share the personal information of individuals under 16 for purposes that would require affirmative authorization under applicable California law.
If we learn that personal information has been collected from a child in circumstances prohibited by applicable law, we will take reasonable steps to address the information as required.
17. Advisory-Client Financial Privacy
This Website Privacy Policy is separate from the financial privacy notice Proflex provides in connection with its investment advisory business.
If you become an advisory client, Proflex may collect additional nonpublic personal information concerning your identity, finances, accounts, investment objectives, transactions, and other matters necessary to provide investment advisory services.
The collection, use, disclosure, safeguarding, and retention of that information may also be governed by Proflex’s financial privacy notice, investment advisory agreement, regulatory obligations, and applicable federal and state financial privacy laws.
Nothing in this Website Privacy Policy reduces any privacy protection provided under those laws or notices.
18. Changes to This Website Privacy Policy
We may update this Website Privacy Policy from time to time to reflect changes in our services, technologies, information practices, or legal requirements.
When we make changes, we will post the revised policy on the Site and update the “Last Updated” date above.
Where applicable law requires additional notice or consent for a material change, we will provide such notice or obtain such consent as required.
19. Contact Us
If you have questions about this Website Privacy Policy or wish to submit an applicable privacy request, please contact:
Proflex Finance LLC
15732 Union Ave, Ste 3036
Los Gatos, CA 95032
Email: contact@proflexfinance.com
Phone: +1 (302) 281-4715