Disclaimer & Privacy Policy

Leo Wealth (collectively, with all Group companies and subsidiaries, the “Group”) conducts business through individual entities that are licensed (where applicable) in different jurisdictions for different businesses. Not all services are available in all markets in which the Group operates. None of the companies in the Group offer legal advice. Clients of the Group should refer to their written agreements with a Group company for further details.

We Take Privacy Seriously

The Group has adopted policies regarding privacy and data protection in accordance with local regulations. We recognize that protecting the privacy and security of the non-public personal information we obtain about our clients is an important responsibility, as is the delivery of personalized, suitable advice. To deliver high quality, personalized services to you, we must collect and maintain certain non-public personal information about you. We want you to know what information we collect and how we use and safeguard that information. For a copy of our current privacy policy, please contact your advisor or call your local office.

What Information We Collect

We collect certain non-public personal information about you (such as your name, address, social security number, passport, etc.) that you provide on applications or other forms as well as communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.). We also collect information about your investments and brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.). Accurate information in critical to us providing you accurate advice and recommendations. As your needs and circumstances change, please contact your advisor immediately to update this information. We can serve you best by fully understanding you and you situation.

What Information We Disclose

We do not disclose the non-public personal information we collect about our clients to anyone except: (1) in furtherance of our business relationship with clients, and then only to those persons necessary to effect the transactions and provide the services that clients authorize (such as broker-dealers, custodians, independent managers etc.); (2) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (3) our group Companies, attorneys, accountants, and auditors; or (4) as otherwise provided by law. We are permitted by law to disclose the non-public personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative services on our behalf). These third parties are prohibited to use or share the information for any other purpose. If you decide to either terminate our services or become an inactive client, we will continue to adhere to our Privacy Policy, as may be amended from time to time. We are required to report any suspected exploitation of vulnerable adult clients to the proper authorities under federal and state statutes.

Security of Your Information

We restrict access to your non-public personal information to those Group companies and employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your non-public personal information.

Changes to Our Privacy Policy or Relationship With You

Our policy about obtaining and disclosing information may change from time to time. We will provide you notice of any material change to this policy before we implement the change. We will make notifications in writing by email or written correspondence. You content to receiving updates via email.

Opting Out

Clients cannot opt out of allowing us to share their non-public personal information with non-affiliated third parties such as custodians, insurance companies and technology service providers which are necessary to service their accounts.

Hong Kong Personal Data Privacy Ordinance Compliance

In addition, in Hong Kong, our policy on Data Collection is designed to conform to the standards laid down by Hong Kong’s Personal Data (Privacy) Ordinance. Leo Capital Hong Kong Limited and Leo Protection Hong Kong Limited (together the “Hong Kong Companies”) have the following policy in regard to use of Personal Data:

This policy is being provided to existing and prospective individual clients of the Hong Kong Companies from whom personal information has been and/or may in the future be collected. Personal information collected from the client (the data) by the Investment Adviser may be used for the purposes of providing investment advisory and management services, direct marketing, and compiling statistics for internal use. We will observe the Ordinance in the collection, maintenance and the use of Data. In particular we will ensure only legitimate means are used to collect Data, the Data used is accurate as possible, the use of the Data is consistent with the Personal Data (Privacy) Ordinance (Cap 486) in Hong Kong and the contractual obligations of the Hong Kong Companies, and the Data is protected and made available only to the authorized persons. Clients have the right to inspect and amend Data any time. Data will only be disclosed consistent with the contractual rights and obligations of the investment adviser to other parties or to other parties authorized by law to receive it. All your personal information held by the Company will be used and disclosed in accordance with the Company Privacy Policy available on request. The client has the right to check whether the Company holds Data about the Client and gain access to such Data, require the Company to correct any inaccurate Data to the Client and ascertain the Company’s policies and practices in relation to Data and be informed of the kind of Data held by the Company.

Requests for Information

For a copy of our Privacy Policy, please contact us in writing at 860 Airport Freeway, Suite 402, Hurst, Texas 76054, or by phone at (817) 354-1090. For a copy of our Hong Kong privacy policy, please contact us in writing at Suites 605-8, 6/F, ICBC Tower, Three Garden Road, Central, Hong Kong, or by phone at +852 3468 8880. For a copy of our Singapore privacy policy, please contact us in writing at 2 Central Blvd, #32-07, Singapore 018916, or by phone at +65 6950 1720.

California Privacy Policy

The Group’s California Privacy Notice supplements the information contained in The Group’s other privacy policies and practices and applies solely to visitors, users, and others who reside in the State of California (”consumers” or “you”) and engage us for investment advisory services, investment advice, insurance services, tax and consulting services, financial planning services, estate planning and wealth management consulting (collectively, “Services”). We provide this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA will have the same meaning when used herein. This notice does not apply to the Group’s clients outside the United States, where other local statutes and ordinances may apply. If you have any questions or comments about this notice, the ways in which The Group collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact your local office or our COO Stephen Tally at +1-817-354-1090.

Changes to our Notices and Policies

We reserve the right to change this California Privacy Notice at any time. If we propose to make any material changes, we will notify you by posting a notice on our website or by issuing an email to the email address listed by account holder(s) prior to the changes becoming effective and update the notice’s effective date. You acknowledge that it is your responsibility to maintain a valid email address as an account holder, and to review our website, Privacy Policy, and this California Privacy Notice periodically to be aware of any modifications. If you do not agree to any changes to the revised Privacy Policy or this California Privacy Notice, you can stop using our Services and close your account with us. However, if you continue to use our Services (including the Website) after we publish a new or updated California Privacy Notice, you acknowledge that such continued use means that the treatment of your personal information will be subject to the new or updated California Privacy Notice.

Security

The Group maintains cyber security policies and practices and provides regular training to employees on these policies. will make every effort to protect the privacy and security of your personal information. We are committed to keeping personal information secure and have implemented the appropriate information security practices, policies, rules and technical measures to protect the personal information under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.

Our employees, consultants, temporary workers and data processors (i.e., those who process your personal information on our behalf and for the purposes listed above) who have access to, and are associated with, processing your personal information are obligated to respect the confidentiality of your personal information and must comply with The Group privacy policies.

Categories and Details of Information We Collect

Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, The Group’s Services have collected the following categories of personal information from its consumers within the last twelve (12) months:

• Identifiers: First name, maiden name, last name, physical address, email address, telephone number, username, Internet Protocol (IP) address, account name.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).: A name, address, telephone number, education, employment, employment history, and, if you are a client, your financial information (including a bank account number.)
• Protected classification characteristics under California or federal law: The Group does not request or require you to provide protected classification characteristics. However, please carefully consider the information contained within your new account application, investor profile and investment management agreement to ensure that you are not providing any protected classification characteristics that are not necessary for your engagement with us as your investment advisor.
• Protected classification characteristics include your age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, genetic information (including familial genetic information), and veteran or military status.

Advisors may request a veteran or military status or marital status in accordance with applicable law, and you may choose whether to submit that information with your new account application.

Commercial information: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, such as details about payments to and from you, and details regarding the services that you have engaged us to provide to you or which investments are included in your portfolio.

Geolocation data, Internet or other similar network activity: IP address, Cookie data and other similar activity concerning an interaction with our Services.

Work/employment-related information: career industry, employer information, years in industry or with current employer, job applications, and any information provided in a resume/CV or employment seeker profile (including, but not limited to, executive summary, objective, current or prior work experience and education). However, please note that The Group has not collected any of the following categories of personal information from consumers within the last twelve (12) months and does not intend to collect such data in the future:

Non-public education information, per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Biometric information (such as genetic, physiological and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, shifts or other biological patterns, and sleep, health, or exercise data) Sensory data (such as audio, electronic, visual, thermal, olfactory, or similar information)

1. Non-Personal Information
   • The Group uses de-identified and/or aggregated consumer information, which is not considered personal information. Deidentified or aggregated data may be derived from your personal information, but is not considered personal information under CCPA, since it does not directly or indirectly reveal your identity
   • We also don’t use information or extensions drawn from other personal information to create a profile or record on you.
2. Sources of Personal Information
   • We obtain the categories of personal information listed above from the following categories of sources:
     • Information coming from you. For example, when you fill in forms, create an account, submit your investor profile, or correspond with us by post, phone, e-mail or otherwise and when you use our Site. Information coming indirectly from you. For example, through automated technologies or your interactions with us, including from observing your actions when you use our Website.
     • Information from Third Parties. We may receive personal information about you from various third parties such as other professionals including, but not limited to, other investment advisors, financial planners, custodians, broker-dealers, accountants, and attorneys. In our capacity as a service provider.
     • Use Of Your Personal Information

We describe in detail in our Customer Privacy Policy Notice the context in which your personal information may be collected, along with how and why we use your personal information. Pursuant to the CCPA, we may use the personal information we collect for one or more of the following business or commercial purposes:

• To fulfill or meet the reason for which the personal information is provided. For example, if you provide your personal information to create an account, we will use that information to create your account and provide investment advice.
• To create, maintain, manage, customize, and/or secure your account with us.
• To communicate with you about your account or our Services, and to manage our relationship with you.
• To provide you with support and to respond to your inquiries, including investigating and address your concerns and monitor and improve our responses.
• To send you communications such as articles, e-newsletters, information on client events, and our services.
• To maintain certain of your information on a suppression list, if you’ve indicated to us that you don’t want to be communicated in a particular way.
• To enable our Website to function properly (ensure proper display of content), create and remember your account login details, and for interface personalization, such as language, or any user-interface customization.
• To provide, support, personalize, and develop our Services.
• To process your requests, transactions, and payments, and prevent transactional fraud.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing or collections, or manage payment disputes or issues with the services.
• To help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business.
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
• For testing, research, analysis, and product development, including to collect statistics and develop and improve our Website or Services.
• For debugging to identify and repair errors that impair existing intended functionality of our Website or Services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA
• The Group will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosures of Personal Information at Your Direction

We disclose your personal information when you intentionally interact with third parties and when you direct us or intentionally use The Group to share your personal information in connection with the services that we provide to you. For example, as an investor, you make seek the services of third parties with whom we have an existing relationships or you may have engaged with a third party mutually. In these circumstances, we may share your personal information with the third party and/or their agents or representatives.

Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure.

1. Disclosures of Personal Information for a Business Purpose
   • We describe in our Customer Privacy Policy Notice the context in which your personal information may be disclosed to or shared with a third party. Pursuant to the CCPA, The Group has disclosed the following categories of personal information for a business purpose in the preceding twelve (12) months:
     • Category A: Identifiers – Name, address, social security number, birthdate
     • Category B: California Customer Records personal information categories
     • Category C: Protected classification characteristics under California or federal law
     • Category D: Commercial information
     • Category G: Professional or employment-related information
   • We may disclose your personal information for a business purpose to the categories of third parties identified in our Customer Privacy Policy Notice, depending on how you use or interact with our Website or Services. This may include disclosure of personal information to the following:
     • Various service providers that we use to support our business, provide services to us, and/or help provide our services to you. Other professionals such as lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, financial planning or consulting, auditing, and accounting services to us so we can provide additional products and services to you to meet your financial needs.
     • Taxing authorities, such as IRD, HMRC, the Internal Revenue Service and other authorities acting as processors who require reporting of processing activities in certain circumstances.
     • Fraud prevention and identity verification services where we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of The Group, our customers or others. This includes exchanging information with third-parties for the purposes of fraud detection and prevention and risk reduction.
     • Law enforcement agencies, courts, supervisory authorities, regulatory bodies and certain other third-parties, to the extent that we are permitted or required to do so by law, or in order to comply with our legal and regulatory obligations, or in the interests of national security, or to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity.
     • To enforce agreements with you, to respond to, and defend ourselves against, claims asserted against us, to protect the rights, property, or safety of The Group, our services, customers or others, or to investigate, prevent, or take action regarding suspected or actual illegal activities or for debt collection.
     • In connection with or during negotiations of any proposed or actual financing, merger, purchase, sale, sale or transfer of some or all of our assets or stock, joint venture, or any other type of financing, acquisition or business combination of our company, or all or any portion of our assets, or transfer of all or a portion of our business to another company.
2. Sale of Personal Information
   • Your privacy is our priority, and we do not monetize your personal information by selling it to third parties.

Contacting Us

If you have any questions or comments about this notice, the ways in which the Group collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact your local office or our COO Stephen Tally at +1-817-354-1090.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how you can exercise them.

Access to Specific Information and Data Portability Requests

You may request that the Group disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Requests below), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, two separate lists disclosing: (i) sales, identifying the personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

   

  1. Requests to Delete Information
     • You may request that The Group delete any or all of your personal information that we collected from you and retained, subject to certain exceptions and limitations under applicable laws. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Requests), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
     • We may deny your deletion request, in whole or in part in accordance with any purpose that is permitted by the CCPA. For example, we may deny your deletion request if retaining the information (or a portion thereof) is necessary for us or our service provider(s) to:
       • Complete the transaction for which we collected the personal information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
       • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
       • Debug products to identify and repair errors that impair existing intended functionality;
       • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
       • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
       • Comply with a legal or regulatory obligation; and/or Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  2. Exercising Access, Data Portability, and Deletion Requests
     • To exercise an access, data portability, or deletion request as described above, please submit a verifiable consumer request to us in one of the following ways:
       • Call +1-817-354-1090 and confirm as to which elements of your information it’s possible for us to delete.
       • If you would like to close your account, please contact your Wealth Manager.
       • Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
     • You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
       • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
       • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it
       • We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
       • We will only use personal information provided in a verifiable consumer request to confirm the requestor’s identity or authority to make the request.
  3. Response Timing and Format of Data
     • We work to respond to a verifiable consumer request within forty-five days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
     • For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, e.g., through an Excel or JSON file format. You may request a particular format and will consider it.
     • We generally do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
     • If for any reason we determine that the request made by you warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
  4. Opting Out from the Sale of Personal Information
     • We do not and do not intend in the future to sell your personal information.
     • We will only use and share your personal information according to this Privacy Policy and as outlined in our Investment Advisor Agreement with you. If we later decide to sell our clients’ personal information, you will be notified immediately and you will be provided with the proper disclosures and the opportunity to exercise your right to “opt-out”.
  5. Non-Discrimination
     • We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
     • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties other than for reasons described in our Form ADV Part 2A or Investment Advisory Agreement.
     • Agreement. Provide you a different level or quality of products or services except as otherwise described in our Form ADV Part 2A or Investment Advisory Agreement.
     • Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services except as otherwise described in our Form ADV Part 2A or Investment Advisory Agreement.

The Group as a Service Provider

In certain instances, a third party may hire us to provide services on behalf of their client. In such case, we process personal information under the direction of that third party as a service provider, and we have no direct relationship with the individuals (investors) whose personal information we process.

Where the Group acts as a service provider, it will collect, retain, use, disclose, and/or otherwise process personal information (i) to fulfill the Group‘s obligations to perform the services pursuant to a written agreement with the third party; (ii) pursuant to a valid business purpose, as permitted under the CCPA; and/or (iii) as otherwise directed by the third party in writing. Where the Group processes personal data in the capacity of a service provider, we will not sell that personal information or otherwise retain, use, or disclose personal information for any commercial purpose, except as otherwise directed by the third party in writing.

In addition to the purposes set forth above, the Group may collect, retain, use, disclose, and otherwise process personal information in the context of a service provider to:

• Comply with all applicable laws;
• Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
• Cooperate with law enforcement agencies concerning conduct or activity that the third party or the Group reasonably and in good faith believes may violate federal, state, or local law;
• Exercise or defend legal claims; and/or
• Collect, use, retain, share, or disclose information that has been aggregated or de-identified, in accordance with the CCPA.
• Where the Group processes your personal data in the capacity of a service provider, and you seek access, or want to correct, amend, or delete your personal data, or have another request, we will provide you with the third party’s contact information, so you can contact them directly. In rare instances, however, circumstances may necessitate we assist you with your question or request. If you have questions about this, please contact us. If you have any questions or comments about this notice, the ways in which The Group collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact your local office or our COO Stephen Tally at +1-817-354-1090.