Privacy Policy

This Privacy Policy (the “Policy”) explains how Zuko and its subsidiaries, including the investment products it sponsors or manages from time to time (collectively, “Zuko,” “we,” “our,” and “us”), collect and protect “Personal Information” (as defined below). If you have any questions that this Policy does not address, please contact us at the email address listed below. By creating an account on any Zuko site (including, without limitation, www.zuko.ai, collectively, the “Zuko site”) or by otherwise submitting Personal Information to us, you consent to the collection and use of your Personal Information as explained in this Policy. This Policy is part of our Terms of Service, and all capitalized terms used but not defined in this Policy have the meanings given to them in the Terms of Service.

Zuko’ Policy applies to current and former Zuko clients and any other users of the Zuko Sites. The term “Personal Information” refers to non-public information that personally relates to or identifies you as an individual or entity.

Updates and Changes to Our Privacy Policy

In the event of a change to this Policy, a revised version will be promptly posted to the Zuko Sites with an updated “Revised” date. The updated version will be effective as soon as it is accessible. You agree to accept posting of a revised Policy on the Zuko Sites as actual notice to you. Any dispute over our Policy is subject to these terms.

How and Why We Gather Information

When you sign up to participate on the Zuko Sites, you may be asked for information such as your full legal name, address, and date of birth, along with other Personal Information required to verify your identity and fulfill our legal and regulatory requirements. This information is used to process your business transactions and communicate with you. We may request additional information from time to time to assess your needs and preferences. We, or our marketing partners acting on our behalf, may also gather Personal Information through the activities of partner advertising services.

We gather and process your Personal Information for various reasons, depending on how you interact with us, including:

  • To facilitate account creation and authentication: We may process your information so you can create and log into your account and keep it in working order.
  • To deliver and facilitate our services: We may process your information to provide you with services you request.
  • To respond to user inquiries/offer support: We may process your information to provide requested assistance.
  • To send you administrative information: We may process your information to send you details about our products and services, changes to our terms and policies, and similar updates.
  • To manage our working relationship with you: We may process your information to manage ongoing relationships and deliver our services.
  • To request feedback: We may process your information to request feedback or contact you about use of our products and services.
  • To send marketing/promotional communications: We may process your Personal Information for our marketing purposes, and you can opt out at any time.
  • To deliver targeted advertising: We may process your information to develop and display personalized content and ads.
  • To protect our services: We may process information to keep our services safe and secure, including fraud prevention.
  • To identify usage trends: We may process information about how you use our services so we can improve them.
  • To determine effectiveness of marketing campaigns: We or our subsidiaries may process your information to optimize promotions and campaigns relevant to you.

Types of Information We Collect

The information we collect and maintain about you may be provided during use of your device, the Zuko Sites, third-party websites, or through signing up for information or transactions involving private issuers that have engaged Zuko. Personal Information may come from the following sources:

  1. Information You Provide
    When you complete forms or request services, we may collect your name, address, age, objectives, job title, experience, assets/liabilities, income details, documentation to verify those details, phone number, email address, and similar data. We may also collect sensitive information such as your social security number and/or taxpayer identification number, as well as other financial details.
  2. Automatically Collected Information
    We may collect device and usage information, such as IP address, browser/device characteristics, operating system, language preferences, referring URLs, country, location, and other technical data about how and when you use our services. Like many companies, we use Cookies (as defined below) and similar technologies. This data is primarily needed for security, service operation, internal analytics, and reporting.
  3. Information from Other Sources
    To enhance our ability to provide marketing, offers, and services—and to update our records—Zuko or certain of its subsidiaries may obtain information (including Personal Information) from public databases, joint marketing partners, affiliate programs, data providers, or other third parties.

How We Protect Your Information

Keeping Information Safe

We limit access to the Personal Information you provide us to employees who need it to deliver services related to your transactions or potential transactions on the Zuko Sites. In keeping with industry standards, we maintain physical, electronic, and procedural safeguards to protect your Personal Information. We regularly review and update our security technology.

The Importance of Being Accurate

Our security standards and procedures are designed to prevent unauthorized access to your Personal Information, and part of that process includes making sure the data we have on file is accurate and up-to-date. If you find inaccuracies in our records or if your Personal Information changes, please notify us immediately.

Your Rights Over Personal Information

Subject to applicable laws and regulations, you have rights regarding your Personal Information, including access, rectification, erasure, blocking, restriction of use, objection to use, data portability, and lodging a claim with your local data protection authority (as applicable). If you would like to discuss or exercise these rights, please contact us using the details at the end of this Policy.

An Ongoing Commitment to Your Privacy

We are just as committed to protecting the privacy of our former clients as current ones. If you become an inactive client, your Personal Information will continue to be protected under the then-current version of this Policy. If you dispose of your investments in any way, Zuko will retain your information as required by regulatory, internal record-keeping, and other legal purposes.

How Information Helps Both You and Us

Information about you and your accounts helps us:

  • Respond more accurately and efficiently to your requests.
  • Secure your investments and protect both you and Zuko from fraud.

Sharing Your Information with Unaffiliated Third Parties

We Limit the Sharing of Information

To protect your privacy, we limit sharing of your Personal Information outside of Zuko and its affiliates. We respect the confidential nature of the information you provide. We do not share Personal Information about you except as outlined below:

  1. Service Providers
    We engage qualified, reputable third parties to help with account processing, client services, or data collection relevant to our business. For each investment made through the Zuko Sites, we may share your Personal Information with third-party providers to perform required background checks, document execution, and execution/clearing services on your behalf.
  2. Business Transfers
    If Zuko or any subsidiary undergoes a corporate sale, merger, reorganization, or similar event, Personal Information may be part of the transferred assets.
  3. Subsidiaries
    We may share information with our subsidiaries if necessary to provide you requested services. A subsidiary is a company we own or control.
  4. Legal and Regulatory Requirements
    Zuko may disclose Personal Information as required by law to regulatory bodies, law enforcement, self-regulatory organizations, or government authorities, or as necessary to credit reporting or collection agencies, or to protect our rights or property.

Notwithstanding the above, all Personal Information shall be handled in accordance with any applicable local legislation, including the General Data Protection Regulation, to the extent Zuko is subject to such regulation.

Reviewing, Changing, or Correcting Information

You are responsible for helping us maintain the accuracy and completeness of your Personal Information. Please review your information regularly to ensure it is correct and up-to-date. If you believe your Personal Information is incorrect or have questions about it, please email us at [email protected].

Third Party Sites

If you choose to purchase a product or service offered by another company, any Personal Information you share with that company is subject to that company’s privacy policies. Except as described herein, we are not responsible for the privacy practices or content of third-party sites or services (each a “Third Party Service”). When you click a link to a Third Party Service, you may be asked for registration or other information; that information goes directly to the third party and is governed by its privacy policy.

Privacy and the Internet

  1. Security Infrastructure
    The Zuko Sites are built on an infrastructure with multiple layers of protection, including industry-standard encryption to safeguard your information.
  2. User Identification and Passwords
    Security is a shared responsibility. Your user identification and password should be kept confidential. If you suspect unauthorized use, discontinue use and notify us.
  3. Cookies
    “Cookies” are small text files that may be placed on your browser when you visit the Zuko Sites. They facilitate navigation by “remembering” your identity (e.g., so you don’t have to input your password repeatedly). You can set your browser to inform you about cookies or to prevent cookies. Declining cookies may reduce functionality or speed.
  4. Web Surfing Data
    We may collect data on your web usage (e.g., pages accessed, frequency of access, preferences) via cookies, web beacons, or page tags. This data can help improve our services. Such data may be shared within Zuko or handled by Third Party Services under our instructions.
  5. Social Media Features
    The Zuko Sites may include social media Features or Widgets (e.g., Facebook Like button). These Features may collect your IP address or set cookies to function properly. They are governed by the privacy policy of their provider.

What Legal Bases Do We Rely On to Process Your Information? (EU/UK Residents)

We rely on the following legal bases to process Personal Information:

  • Consent: You can withdraw consent at any time.
  • Performance of a Contract: We process Personal Information to fulfill our contract with you.
  • Legitimate Interests: We process data to pursue our business interests, as long as those do not override your fundamental rights.
  • Legal Obligations: We may process information to comply with legal or regulatory requirements.
  • Vital Interests: We may process information to protect your vital interests or those of a third party.

Statutory Disclosures

We have collected (or our business partners have collected) various categories of Personal Information in the past twelve (12) months. The chart below outlines categories, examples, and whether they are collected:

Category

Examples

Collected

A. Identifiers

Contact details (real name, alias, postal address, phone, email, account name, IP)

YES

B. Personal information categories

Name, contact info, education, employment, financial info

YES

C. Protected classification characteristics

Gender, date of birth

YES

D. Commercial information

Transaction details, purchase history, payment data

YES

E. Biometric information

Fingerprints, voiceprints

NO

F. Internet or other similar activity

Browsing history, search history, online behavior

YES

G. Geolocation data

Device location data

YES

H. Audio, electronic, visual info

Images, audio, video, call recordings related to business activities

NO

I. Professional or employment-related

Business contact details, job title, work history, qualifications

YES

J. Education information

Student records, directory information

NO

K. Inferences drawn

Profile or summary about preferences, characteristics

YES

Zuko has not sold any Personal Information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed certain categories of Personal Information (A, B, C, D, F, G, I) to third parties for business or commercial purposes in the same period.

Your Rights with Respect to Personal Information

  1. Right to Request Deletion
    You can request that we delete your Personal Information, subject to exceptions provided by law or regulation.
  2. Right to Be Informed
    Depending on circumstances, you have the right to know:
    • Whether we collect and use your Personal Information.
    • The categories of Personal Information collected.
    • The purposes for which that information is used.
    • Whether we sell Personal Information to third parties.
    • The categories of Personal Information sold or disclosed for a business purpose.
    • The categories of third parties to whom Personal Information was sold or disclosed.
    • The business or commercial purpose for collecting or selling Personal Information.
  3. Right to Non-Discrimination
    We will not discriminate against you for exercising these rights.
  4. Verification Process
    We may need to verify your identity when you request to exercise privacy rights, such as providing additional information to match our records.
  5. Other Privacy Rights
    • You may object to the processing of your Personal Information.
    • You may request correction or restriction of use.
    • You can designate an authorized agent to make requests on your behalf, subject to verification.
    • You may opt out of future sales of Personal Information.

To exercise these rights, please contact us at [email protected].

CalOPPA Disclosures

Do Not Track Signals

We do not currently respond to “Do Not Track” signals. If this changes, we will update this Policy.

Minors

We do not knowingly solicit or market to children under 18. By using our services, you represent that you are at least 18. If we learn that Personal Information from anyone under 18 has been collected, we will delete such data promptly. If you become aware of such collection, please contact us.

Third Party Data Collection

We may authorize certain third parties (e.g., Google Analytics) to track usage and collect information about users on the Zuko Sites or other Zuko assets.

Contact Us

For any questions or comments regarding this Policy—or to request changes to your Personal Information—please email us at [email protected]

Last Revised: 09-01-2025