Disclosures & Privacy Policy

Last Updated: September 19, 2024

Our Commitment to Your Privacy

At Inicio Inc. DBA Pomarium ("Pomarium," "we," "us," or "our"), our mission is to empower financial advisors ("you") by providing an interactive web-based investment tool that helps you select tailored investment strategies for your clients. We are committed to protecting your privacy and ensuring the security of your personal information.

This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our website and the Beta Service (collectively, the "Services"). By accessing or using our Services, you agree to the terms of this Privacy Policy.

1. Definitions

"Services": The software, web pages, analyses, and any information accessible through our website, including any updates or modifications we make.

"Financial Advisors": Registered investment advisors or sophisticated investors who use Pomarium's Services to select investment strategies for their clients.

"Clients": The clients of Financial Advisors.

"Users": All users of Pomarium's Services, including Financial Advisors and their authorized personnel.

2. Information We Collect

2.1 Information You Provide to Us

We collect information that you voluntarily provide when you use our Services, including:

Account Information: To create an account, you must provide your name, email address, company name, and password. This information is not public.

Client Information: Financial Advisors may input client information, such as names, contact details, investment preferences, and survey responses. Providing client information is optional and used solely to enhance the Services for your benefit.

Content Submissions: Any content you submit through the Services, including text, documents, and other materials.

Communications: Information you provide when you contact us for support, provide feedback, or otherwise communicate with us.

2.2 Information We Collect Automatically

When you use our Services, we may automatically collect:

Usage Data: Information about your interactions with the Services, such as pages visited, features used, time spent on the Services, and other diagnostic data.

Log Data: Technical information including your IP address, browser type, operating system, referral URLs, device information, and timestamps.

Cookies and Similar Technologies: We use cookies and similar tracking technologies to enhance your experience, analyze usage, and personalize content.

3. How We Use Your Information

We use the information we collect for various purposes, including:

Providing and Maintaining the Services: To operate and improve our Services, process transactions, and provide customer support.

Personalization: To tailor the Services to your preferences and enhance your user experience.

Communication: To send administrative information, respond to inquiries, and provide updates about the Services.

Analytics and Development: To monitor usage, perform data analysis, and improve the functionality and security of the Services.

Legal Compliance: To enforce our agreements, comply with legal obligations, and protect our rights and the rights of others.

4. Legal Basis for Processing Personal Data

We process your personal information based on the following legal grounds:

Performance of a Contract: Processing is necessary to provide the Services as outlined in our agreement with you.

Legitimate Interests: We have a legitimate interest in processing your data to improve our Services, provided that such processing does not outweigh your rights.

Consent: We may process your information based on your consent, which you can withdraw at any time.

Compliance with Legal Obligations: Processing is necessary to comply with applicable laws and regulations.

5. How We Share Your Information

We do not sell or rent your personal information. We may share your information in the following circumstances:

5.1 With Service Providers

We may share information with third-party vendors and service providers who perform services on our behalf, such as:

IT and System Administration: Hosting providers, data storage services, and maintenance services.

Analytics Providers: Companies that assist us in analyzing how our Services are used.

These third parties are obligated to maintain the confidentiality of your information and are restricted from using it for any purpose other than providing services to us.

5.2 For Legal Reasons

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including:

Compliance with Laws: To comply with legal obligations, regulations, legal processes, or governmental requests.

Protection of Rights: To enforce our terms and policies, protect our operations, and protect the rights, privacy, safety, or property of Pomarium, you, or others.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction.

5.4 Aggregated and De-Identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you, for purposes such as:

Research and Development: To improve our Services and develop new features.

Marketing: To promote our Services without disclosing personal information.

6. Your Choices and Rights

6.1 Access and Update Your Information

You can access, correct, or update your account information at any time by logging into your account settings or contacting us directly.

6.2 Data Portability

You have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format.

6.3 Opt-Out of Communications

You may opt out of receiving promotional communications from us by following the unsubscribe instructions in those communications or by contacting us.

6.4 Deletion of Your Information

You may request that we delete your personal information. We will comply with your request unless we are legally required or have a legitimate business purpose to retain certain information.

6.5 Clients' Personal Information

As a Financial Advisor, you are responsible for obtaining the necessary consents from your clients before providing their personal information to us. Clients should contact their Financial Advisor to exercise their rights regarding their personal information.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to:

Enhance User Experience: Remember your settings and preferences.

Analyze Usage: Monitor and analyze trends, usage, and activities.

Managing Cookies: You can set your browser to refuse cookies or alert you when cookies are being sent. However, disabling cookies may affect the functionality of the Services.

8. Information Security

We implement reasonable administrative, technical, and physical safeguards to protect your information from unauthorized access, disclosure, alteration, or destruction. These measures include:

Encryption: Using SSL/TLS protocols to encrypt data transmission.

Access Controls: Limiting access to personal information to authorized personnel only.

Security Assessments: Regularly reviewing our security practices to enhance data protection.

However, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.

9. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Factors influencing our retention periods include:

Legal Obligations: Compliance with legal, tax, and regulatory requirements.

Dispute Resolution: Handling disputes and enforcing our agreements.

Business Operations: Maintaining accurate business and financial records.

10. Children's Privacy

Our Services are intended for use by individuals who are at least 18 years old. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

11. International Data Transfers

Your information may be transferred to, stored, and processed in countries other than your own, including the United States, where our servers are located. We take appropriate measures to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by:

Posting the updated policy on this page with a new "Last Updated" date.

Email Notification: Sending an email to the address associated with your account.

We encourage you to review this Privacy Policy periodically to stay informed about our data practices.

13. Contact Us

If you have any questions, concerns, or comments about this Privacy Policy or our data practices, please contact us at:

Inicio Inc. DBA Pomarium

[email protected]

320 E Vine Suite 120, Fort Collins, CO 80524