=Effective Date: November 25, 2025

This Privacy Policy describes how [NOME DA ENTIDADE LEGAL DA DELTA CAPITAL PRO] (operating as Delta Capital Pro), along with its affiliates and service providers, collects, uses, shares, and protects your personal information. As an entity engaged in strategic asset management, we comply with relevant U.S. federal and state laws, including the Gramm-Leach-Bliley Act (GLBA), and adhere to compliance standards appropriate for our operations with U.S.-regulated financial products.

1. Our Commitment to Privacy and Compliance

Delta Capital Pro operates under a framework of strict data confidentiality, essential to managing high-net-worth individual data.

• U.S. Operations & Compliance: Our strategic and operational activities are anchored in the U.S. (Atlanta, Georgia), and our assets are managed in partnership with highly regulated U.S. brokerages (like Tastytrade). We adhere to relevant record-keeping and privacy standards, including those set forth by the Securities and Exchange Commission (SEC), reflecting our status as an SEC-registered or compliant entity.

• Nonpublic Personal Information (NPI): We treat all client financial information as confidential NPI, safeguarding it as required by U.S. financial privacy standards.

2. Information We Collect

We primarily collect Nonpublic Personal Information (NPI) and Personally Identifiable Information (PII) necessary for providing strategic asset management services.

2.1. Information Provided Directly By You (NPI/PII):

This includes information provided during consultations, onboarding, and through our secure access forms:

• Contact Data: Name, address, phone number, email address.

• Financial Data: Estimated investment capital, assets, liabilities, income, tax identification number, and banking information necessary for fund transfer (handled via secure partnership channels).

• Verification Data (KYC): Social Security Number (SSN) or Tax ID, date of birth, and background screening results required for client verification.

2.2. Information Collected Automatically:

When you use our Website, we automatically collect:

• Technical Data: IP address, browser type, device information, operating system.

• Usage Data: Pages visited, time spent on the Website, click patterns, and referring website addresses (via Cookies).

2.3. Information from Third Parties:

We may receive NPI from authorized third parties, including:

• U.S. regulated brokerage partners (e.g., Tastytrade) for performance and custodial data.

• Background check and identity verification services.

• Financial custodians, auditors, and legal counsel.

3. How We Use Your Information

We use your NPI/PII primarily to service your account, maintain compliance, and improve our services:

• Service Delivery: To manage your assets, execute investment strategies (e.g., Delta Trading Pro), and provide personalized performance reports.

• Security and Compliance: To verify identity (KYC/AML), detect and prevent fraud, and comply with legal or regulatory requirements (e.g., SEC record-keeping rules).

• Communication: To provide service updates, market insights, and information relevant to your strategic partnership.

• Internal Analysis: To assess website usage, improve service offerings, and refine strategies.

4. Disclosure and Sharing of Information

We do not sell your NPI to anyone. We share your information only when necessary to service your account or as required by law, strictly following GLBA requirements.

4.1. Sharing with Affiliates and Service Providers:

We may share NPI with:

• Affiliates: Entities controlled by or under common control with Delta Capital Pro (for internal business purposes).

• Non-Affiliated Service Providers: Parties that perform services on our behalf, such as:

  • Custodial and execution brokerages (e.g., Tastytrade).

  • Auditors, attorneys, and compliance consultants.

  • Technology vendors providing platform security and data aggregation.

4.2. Legal and Regulatory Disclosure:

We may disclose your NPI when required to do so by law, court order, or governmental authority, including the SEC, FINRA, or other regulatory bodies with jurisdiction over our operations.

5. Data Security and Protection

We implement robust physical, electronic, and procedural safeguards to protect your NPI.

• Encryption: We use advanced encryption methods (SSL/TLS) to protect data transmitted over the internet.

• Access Control: Access to NPI is restricted to employees and agents who require the information to service your account. All employees are trained on confidentiality protocols.

6. Your Rights and Choices (U.S. Guidelines)

You have certain rights regarding your personal information, consistent with general U.S. standards (including principles similar to the CCPA/CPRA):

6.1. Right to Opt-Out of Sharing (GLBA):

You have the right to direct us not to share your NPI with non-affiliated third parties, except for those necessary to service your account (e.g., your broker or custodian) or those legally required.

6.2. Right to Know and Delete (CCPA Principles):

You may have the right to request:

• Right to Know: What specific pieces of personal information we have collected about you.

• Right to Delete: The deletion of personal information that we have collected from you, subject to legal retention obligations (e.g., financial record-keeping required by the SEC).

6.3. Exercising Your Rights:

To exercise any of these rights, please submit a request to our support team using the contact information provided below. We will verify and respond to your request as required by applicable law.

7. Changes to This Privacy Policy

We may update this policy periodically to reflect changes in our practices or applicable laws. Any changes will be posted on this page with a revised "Effective Date."

8. Contact Information

If you have any questions or concerns regarding this Privacy Policy, your rights, or the handling of your data, please contact us:

• Email: [SUPORTE GERAL E-MAIL] (e.g., info@deltacapitalpro.com)

• Address: [ENDEREÇO COMPLETO DA SEDE/REGISTRO DA DELTA CAPITAL PRO]