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AGHAZ INVESTMENT ADVISORS, LLC
Phone: (425) 202-6196
Email: info@aghazinvest.com
September 2022
Privacy Policy
Investment Advisers are required by Federal law to inform their clients of their policies regarding privacy of client information. Aghaz
Investment Advisors, LLC (referred to herein as the “Company” or “Firm” or “Aghaz”) appreciates the trust our clients place in us, and we
recognize the importance of protecting the confidentiality of non-public personal information that we collect from them through our
business relationships. The information is used to ensure accuracy in reporting and record keeping, to perform our regular course of
business, and to comply with the law and our regulators.
As a registered investment adviser under the SEC Rule 203A-2(e) the Firm provides investment advice to advisory clients exclusively
through an interactive website. Toward this end, the Company’s investment management services are offered online only to individual
separate accounts (each a “Client” and collectively, “Clients”). As is true of many digital platforms, we collect certain information about
you automatically through our websites, mobile apps, and other online offerings (collectively, the “Offerings”). Keeping this information
secure is a top priority for us, and we are pleased to share with you our Privacy Policy:
1. We collect non-public personal information about our clients from the following sources:
a. Applications (e.g., brokerage account applications)
b. Our Investment Management Agreement
c. Records of accounts under our management
d. Other forms, correspondence, and communications
e. We collect information about your activity, which includes device identifiers (like IP address or mobile device identifiers),
pages or features you use, time and date of access, and other similar usage information
f. Identity data, such as your name, date of birth, and other data on government-issued identification documents
g. Contact data, such as your email address, mailing address, and telephone number
h. Transactional information. When you receive, submit, or complete a transaction via the Offerings, we collect information
about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction
i. Financial data, such as your bank account and payment card details, and information about your income, account balances,
financial transaction history, credit history, tax information, and credit scores
j. Profile data, such as your username and password
k. Stored content, such as photos from your mobile phone gallery or contacts stored in your mobile device or email accounts.
We only collect this information with your permission
l. Additional data you provide, such as via survey responses, customer support, or other means.
2. While using the Firm’s application, in order to provide features, the Firm may collect, with you prior permission: Information from
your Device’s phone book (contacts list). We use this information to provide features of our service, to improve and customize
our service. The information is not uploaded or stored to the Company's servers. You can enable or disable access to this
information at any time, through your device settings.
3. Location data. We may collect the GPS location of your mobile device in accordance with your device permissions. You can
stop the collection of this precise location information at any time (see the Your Control section below for details). Google uses
technologies to approximate your location, including IP address (see Google’s Privacy Policy located at
https://policies.google.com/privacy to learn more about how they process this information). We also approximate your location
by your IP address.
4. Information collected through tracking technologies. We and our service providers also use technologies, including cookies and
web beacons, to automatically collect certain types of usage and device information when you use our Offerings or interact with
our emails. The information collected through these technologies includes your IP address, browser type, Internet service
provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage information
and other similar information.
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5. We maintain administrative, physical and electronic safeguards to protect non-public personal information.
6. If you link, connect, or log in to your Aghaz Account with a third-party service (e.g., Google, Apple), the third-party service may
send us information such as your profile information from that service. This information varies and is controlled by that service
or as authorized by you via your privacy settings at that service.
7. Advertising Data. We collect information in connection with our ad campaigns that surfaced on other platforms, such as the ads
you clicked on and other interactions with our ads.
8. We may disclose non-public personal information about our clients and former clients to employees, independent contractors,
or other third parties with whom we have contracted to perform services on our behalf, such as brokerage, legal, accounting,
compliance, and data processing services, as well as in order to comply with legal and regulatory requests made to us, and to
assist with law enforcement, investigations, complaints, regulatory requests, litigation, arbitration, mediation, and other legal
processes.
9. Note that our Privacy Policy includes no right to disseminate non-public personal information about our clients and former clients
to any external or third party for marketing or other purposes not directly related to servicing your account.
10. We may disclose non-public personal information about our clients and former clients as required by Federal, state, or local law.
We will provide notice of changes in our information sharing practices. If, at any time in the future, it is necessary to disclose any
of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change
so you will have the opportunity to opt-out of such disclosure. In addition, we share information about you with third-party vendors
and service providers who perform services for us, such as identification verification, fraud prevention, advertising, mailing
services, tax and accounting services, contest fulfillment, web hosting, and analytics services.
11. The Firm uses third-party services. For example, we use Google Analytics and you can review the “How Google uses information
from sites or apps that use our services” linked here: http://www.google.com/policies/privacy/partners/ for information about how
Google processes the information it collects. These companies collect information about your use of our Offerings and other
websites and online services over time through cookies, device identifiers, or other tracking technologies. The information
collected includes your IP address, web browser, mobile network information, pages viewed, time spent, links clicked, and
conversion information. For more information about interest-based ads, including to learn about options for opting out of having
your web browsing information used for targeted advertising purposes, please visit www.aboutads.info/choices. You should also
review your mobile device settings and controls for features that allow you to opt out or opt in to having certain information
collected for behavioral advertising purposes. Please note, as an investment adviser we do not advertise on behalf of specific
securities or investment options on our Offerings.
Other Important Information:
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For California residents: We will not share information we collect about you with nonaffiliated third parties, except as permitted
by law. We will not share information about your creditworthiness with our affiliates, as applicable, other than as permitted by
California law, unless you authorize us to make those disclosures.
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For Nevada clients: Section 340 of the Nevada Privacy Law requires that an operator post a privacy policy, which is called a
“notice” in Nevada. We are providing you this notice pursuant to state law. We will not share information we collect about you
with nonaffiliated third parties, except as permitted by law. We will not share information about your creditworthiness with our
affiliates, as applicable, other than as permitted by Nevada law, unless you authorize us to make those disclosures.
•
For Vermont residents: We will not share information we collect about you with nonaffiliated third parties, except as permitted
by law, including, for example with your consent or to service your account. We will not share information about your
creditworthiness with our affiliates, other than as permitted by Vermont law, unless you authorize us to make those disclosures.
Aghaz is an investment adviser registered with the Securities and Exchange Commission (The "SEC") under The Securities Exchange
Act of 1934 ("The Act"), specifically as an Internet adviser relying on rule 203A-2(e), as well as with the Financial Industry Regulatory
Authority (the "FINRA"). The Firm is committed to safeguarding the confidential information of our clients. We will provide notice of
changes in our information sharing practices. If, at any time in the future, it is necessary to disclose any of your personal information in a
way that is inconsistent with this policy, we will give you advance notice of the proposed change so you will have the opportunity to opt
out of such disclosure.