Disclosures & Privacy Policy

At Pomarium, protecting your privacy is a priority. Although we do not directly provide investment advice to clients, we collect certain information necessary to operate our platform for financial professionals. We are committed to confidentiality, security, and transparency regarding how we collect, share, and protect client information.

Types of Nonpublic Personal Information (NPI) We Collect

We collect NPI that is either provided to us by your Financial Professional or obtained through your authorized input on our platform. This includes:

Personal Identifiers: Name and contact information.

Financial Data: Information related to investment preferences, goals, and values-based criteria shared to enhance the accuracy of Pomarium’s investment analysis.

Information Sharing

We share personal information only for specific, limited purposes:

Business Operations: Generating personalized Pomarium Output and maintaining secure platform access.

Service Providers: Trusted third-party vendors who assist with data storage and security under strict confidentiality agreements.

Legal Compliance: When necessary to comply with court orders, regulatory requests, or legal investigations.

Note: Pomarium does not sell, lease, or trade your personal information for marketing purposes.

How We Protect Your Information

To secure your data, Pomarium follows strict protocols:

Encryption: Data is encrypted during both storage and transmission.

Access Controls: Secure network architecture designed to meet federal and industry standards.

Retention: Data is kept only as long as necessary to fulfill the purposes outlined in this policy or as required by law.

Your Rights to Limit Sharing

Federal law grants certain rights to limit sharing. Pomarium does not share personal data with affiliates for marketing purposes or with non-affiliates except as necessary for service delivery. To opt out of any applicable information sharing, please notify us through your Financial Professional.

California Privacy Policy

Pomarium (provided by Inicio Inc.) complies with the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

Information We Collect

We may collect the following categories of personal information:

Identifiers: Name and contact details.

Financial Information: Investment preferences and goals used to generate Pomarium Output.

Internet Activity: IP addresses and usage data related to platform interactions.

Pomarium does not directly collect sensitive personal information like Social Security numbers or banking details.

Your Privacy Rights

As a California resident, you have the following rights:

Right to Know: Request details on what data is collected and how it is used.

Right to Delete: Request the deletion of your data (subject to legal exceptions).

Right to Correct: Request the correction of inaccurate data.

Right to Opt-Out/Limit: Opt out of non-essential sharing or limit the use of sensitive data.

Exercising Your Rights

To exercise these rights, you or an authorized representative may contact us via:

Email: info@getpomarium.com

Subject Line: "California Privacy Rights Request"

We will confirm receipt within 10 days and respond within the timeframes required by California law. We will not discriminate against any user for exercising these rights.

If you have questions regarding this policy, please reach out to your Financial Professional or email us directly at info@getpomarium.com.

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Terms, Conditions, Privacy & Disclosures

Data in this report pertain only to social impact, not financial performance. Pomarium is not an investment advisor and does not provide investment advice or investment recommendations. The information contained herein is believed to be from reliable sources, but we make no warranty or guarantee as to the accuracy of the information. Information presented may change over time based on market or other conditions without notice. Please consult with your advisor for more details about any of the metrics displayed in this report.

Links to external websites are strictly as a courtesy. We make no representation as to the completeness or accuracy of information provided in the web links within this report. Nor is Pomarium liable for any direct or indirect technical or system issues or any consequences arising out of your access to or your use of third-party technologies, websites, information, and programs made available through this report. When you access one of these links, you assume total responsibility and risk for your use of the websites.

Investing involves risk. Depending on the types of investments, there may be varying degrees of risk. Socially responsible investing does not guarantee any amount of success. This analysis may not provide a complete picture of the social impact as it is only as reliable as the amount of data available.