Privacy Notice

Devancore ("we," "our," or "us") is committed to protecting your privacy. This Privacy Notice explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services. Devancore operates in a controlled access environment, working with selected broker-dealers and custody partners to process live trading data in U.S. regulated markets.

1. Information We Collect

1.1. Information You Provide

When you use our contact form or request information, we may collect:

• Name and professional contact information
• Email address
• Organization name and details
• Any information you voluntarily provide in communications

1.2. Information Collected Automatically

When you visit our website, we may automatically collect:

• IP address and browser type
• Device information and operating system
• Pages visited and time spent on pages
• Referring website addresses
• Cookies and similar tracking technologies

1.3. Trading and Operational Data

In our operational environment, Devancore processes live trading data on behalf of selected broker-dealers and custody partners. This data is handled in accordance with strict security protocols, regulatory requirements (including SEC Rule 17a-4 and FINRA regulations), and contractual agreements with our institutional partners. Trading data is not collected through this public website.

2. How We Use Your Information

We use the information we collect to:

• Respond to your inquiries and provide requested information about Devancore
• Communicate with you about our services and platform capabilities
• Improve our website and user experience
• Comply with legal obligations and regulatory requirements
• Protect against fraud, security threats, and unauthorized access
• Analyze website usage patterns to enhance our services

3. Information Sharing and Disclosure

3.1. Service Providers

We may share your information with third-party service providers who assist us in:

• Website hosting and maintenance
• Email communication services
• Analytics and performance monitoring

3.2. Institutional Partners

Devancore operates in a controlled access environment with selected broker-dealers and custody partners. Trading and operational data processed through our platform is shared only with authorized institutional partners under strict confidentiality agreements and in compliance with applicable securities regulations.

3.3. Legal Requirements

We may disclose your information if required by law, regulation, court order, or governmental authority, including but not limited to SEC, FINRA, or other financial regulatory bodies.

4. Subprocessors

5. Data Residency

The devancore.com marketing site is hosted on AWS infrastructure in the United States. No visitor data is intentionally transferred outside the United States by Devancore.

6. Data Security

Devancore implements industry-standard security measures to protect your information, including encryption, access controls, and regular security assessments. Our platform is designed to meet SEC Rule 17a-4 compliance requirements and follows FINRA guidelines for data protection. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Enhance website functionality and user experience
• Analyze website traffic and usage patterns
• Remember your preferences and settings

You can control cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of our website.

8. Your Rights (CCPA & GDPR)

8.1. California Consumer Privacy Act (CCPA)

If you are a California resident, you have the right to:

• Know what personal information we collect, use, and disclose
• Request deletion of your personal information
• Opt-out of the sale of personal information (we do not sell personal information)
• Non-discrimination for exercising your privacy rights

8.2. General Data Protection Regulation (GDPR)

If you are located in the European Economic Area (EEA), you have the right to:

• Access your personal data
• Rectify inaccurate personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Data portability
• Withdraw consent at any time

9. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law. Trading and operational data are retained in accordance with SEC Rule 17a-4 requirements and our agreements with institutional partners.

10. Children's Privacy

Our website and services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

11. Stealth Mode and Limited Disclosure

Devancore currently operates in a controlled access, stealth mode environment. We work with a select group of broker-dealers and custody partners to process live trading data. Due to the sensitive nature of our operations and regulatory requirements, certain information about our platform, partners, and operations may not be publicly disclosed. This Privacy Notice applies to information collected through our public website and initial contact communications.

12. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The "Last updated" date at the top of this page indicates when this Privacy Notice was last revised. Your continued use of our website after any changes constitutes your acceptance of the updated Privacy Notice.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Notice or our data practices, please contact us at:

Email: solutions@devancore.com

For requests related to your privacy rights under CCPA or GDPR, please include "Privacy Request" in the subject line of your email and specify which right you wish to exercise.

By using our website or contacting us, you acknowledge that you have read and understood this Privacy Notice and agree to the collection, use, and disclosure of your information as described herein.