Notice of Privacy Policy & Practices

Your privacy is very important to us. This notice is provided by Alpha RIA LLC (Alpha, the firm, us, we, or our). This Privacy Notice sets forth our policies with respect to non-public personal information about our investors and clients and prospective and former investors and clients. For purposes of this notice, the terms “customer” or “client” include both (i) individuals who have a continuing client relationship with the firm (e.g., by having an investment advisory contract with the firm or by holding an investment product through the firm) and (ii) individuals who provide nonpublic personal information to the firm, but who do not have a continuing relationship with the firm (e.g., an individual who provides such information in deciding whether to become a client, whether or not the individual establishes a continuing relationship with the firm).

We recognize and respect the privacy expectations of our clients. We provide this notice to you so that you will know what kinds of information we collect about our customers and the circumstances in which that information may be disclosed to third parties who are not affiliated with us. If you are a corporate customer (including, for these purposes, legal arrangements such as personal investment companies, trusts, or limited partnerships) that provides us with personal information on individuals connected to you for any reason in relation to your business with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

These policies apply to investors in our separately managed account (SMA) portfolios and other clients. These policies may be changed at any time, provided a notice of such change is given to you.

Collection of Your Information
We collect the following nonpublic personal information about our customers:

  • Information from the customer
  • Information about the customer’s transactions with us or our affiliates
  • Information about the customer’s transactions with non-affiliated third parties
    Information from these sources can include:
  • Account Applications and other forms, which may include a customer’s name, address, passport information, social security number, and information about a customer’s investment goals and risk tolerance
  • Account History, including information about the transactions and balances in a customer’s account
  • Correspondence, written, telephonic, or electronic, between a customer and Alpha or service providers to Alpha. Among other sources, we may collect this information through Internet web sites

Disclosure of Your Information
We may disclose all of the information described above to certain third parties who are not affiliated with us under one or more of the following

  • As Authorized – if you request or authorize disclosure of the information.
  • As Required by Law – for example, to cooperate with regulators or law enforcement authorities.
  • As Otherwise Permitted by Law – to organizations with which we are not affiliated, if doing so is necessary to provide the service you are
    buying (“Service Providers”) – for example, sharing information with companies that maintain, process, or service your accounts or financial products
    and services or effect, administer, or enforce your transactions is permitted. Among other activities, we may share information with broker-dealers in
    order to execute your trades or with custodians that hold securities on your behalf. We may also share your personal information with organizations who provide services to our firm, including lawyers, auditors, accountants, brokers, AML service providers, tax information exchange service providers, or other back office service providers. We believe that sharing of information for these purposes is essential to providing you with necessary or useful services with respect to your accounts.

Security of Your Information
We require our Service Providers:

  • to maintain policies and procedures designed to assure only appropriate access to information about our customers
  • to limit the use of information about our customers to the purposes for which the information was disclosed, or as otherwise permitted by law
  • to maintain physical, electronic and procedural safeguards that comply with federal standards to guard non-public personal information about our customers.

We will adhere to the policies and practices described in this notice regardless of whether you are a current or former client of Alpha.

Opting Out
Before we may disclose non-public personal information about any consumer (including any client or customer) to a non-affiliated third party other than a Service Provider and other than pursuant to one of the exceptions under Regulation S-P, we must provide each consumer an initial privacy policy notice and an opt-out notice. The opt-out notice would describe our planned disclosures and give customers a reasonable opportunity to decline permission to make those disclosures. Because we do not disclose non-public personal information to non-affiliated third parties, other than Service Providers or pursuant to the exceptions, we are not required to provide opt out notices.

Information Security
Within Alpha, access to information about you is restricted to those employees who need to know the information to service your account. Our employees are trained to follow our procedures to protect your privacy and are instructed to access information about you only when they have a business reason to obtain it. We use physical, electronic and procedural safeguards to keep your information secure.

California Consumer Rights
Under California law, residents of California have the right to know what personal data is being collected about them, know whether their personal data is being sold or disclosed, opt out of the sale of their personal data, access their personal data, request deletion of their personal data, and have equal service and price even if they exercise their privacy rights. To exercise those rights, the California resident should call +1 (212) 933-9301. We do not sell any customer data.

Effective as of March 31, 2021

Your privacy is important to us and maintaining your trust is our priority. Alpha RIA LLC, (“Alpha,” “we,” “our,” or “us”), respects your privacy and is committed to protecting it through our compliance with this California Privacy Notice. We believe you have the right to know what information we collect, how we use it and what security measures we have taken and will continue to take to protect your information.

This California Privacy Notice supplements the information contained in Alpha’s Customer Privacy Policy Notice 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 (“Services”). We adopt 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 in this notice. Capitalized terms used but not otherwise defined herein or in the CCPA shall have the meanings given to such terms in our Privacy Policy Notice.

1. Information We Collect

a. Personal Information

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, Alpha’s Services have collected the following categories of personal information from its consumers within the last twelve (12) months:

  1. Identifiers: First name, maiden name, last name, physical address, email address, telephone number, username, Internet Protocol (IP) address, account name.
  2. 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.) Some personal information included in this category may overlap with other categories.
  3. Protected classification characteristics under California or federal law: Alpha 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.
  4. 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.
  5. Internet or other similar network activity: Cookie data and other similar activity concerning an interaction with our Services.
  6. Geolocation data: IP Address.
  7. Professional or employment-related information: Job industry, employer information, years in industry or with current employer, job applications, and any information provided in a resume/CV or job seeker profile (including, but not limited to, executive summary, objective, current or prior work experience and education).
  8. Inferences drawn from other personal information to create a profile: None.

Note: Alpha has not collected any of the following categories of personal information from consumers within the last twelve (12) months:

  • Biometric information (such as genetic, physiological, behavioral, 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, gait, or other physical patterns, and sleep, health, or exercise data)
  • Sensory data (such as audio, electronic, visual, thermal, olfactory, or similar information)
  • 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.

b. Non-Personal Information

Alpha uses de-identified and/or aggregated consumer information, which is not considered personal information. De-identified 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. For example, we may aggregate your Internet or other similar network activity to calculate the percentage of users accessing a specific website feature.

c. Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly 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.
  • Indirectly from you. For example, through automated technologies or your interactions with us, including from observing your actions when you use our Website.
  • 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 (see Section 5. below).

2. Use Of 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.
  • 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, including without limitation in the event of a divestiture, restructuring, reorganization, dissolution or other event, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Alpha is among the assets transferred.

Alpha 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.

3. Sharing Personal Information

a. 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 Alpha 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 relationship or you may have participated in an event hosted by us and a third party. 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.

b. 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, Alpha 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:

  • Service providers that we use to support our business, provide services to us, and/or help provide our services to you.
  • 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 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 Alpha, 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 Alpha, 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.

c. Sale of Personal Information

Your privacy is our priority, and we do not monetize your personal information by selling it to third parties. We simply never ever sell your personal information, period.

4. 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.

a. Access to Specific Information and Data Portability Requests

You may request that Alpha 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.

b. Deletion Requests

You may request that Alpha delete any of your personal information we collected from you and retained, subject to certain exceptions. 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 obligation
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it

c. 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:

  • Send an email to to inquire 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 Investment Advisor Representative (IAR) as per Form ADV 2B that you were provided. If you are unsure who your IAR is, please call us.

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.

d. Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) 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 Numbers file format.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

e. Opting Out from the Sale of Personal Information

We do not 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”.

f. 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 Contract.
  • Provide you a different level or quality of products or services except as otherwise described in our Form ADV Part 2A or Investment Advisory Contract.
  • 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 Contract.

5. Alpha as a Service Provider

In certain instances, a third party may hire Alpha 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 Alpha acts as a service provider, it will collect, retain, use, disclose, and/or otherwise process personal information (i) to fulfill Alpha‘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 Alpha 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, Alpha may collect, retain, use, disclose, and otherwise process personal information in the context of a service provider to:

  • Comply with 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 Alpha reasonably and in good faith believes may violate federal, state, or local law
  • Exercise or defend legal claims
  • Collect, use, retain, share, or disclose information that has been aggregated or de-identified, in accordance with the CCPA

Where Alpha 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.

6. Security

Alpha 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 Alpha’s privacy policies.

7. Changes to This California Privacy Notice

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 in order to be aware of any modifications. If you object 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.

8. Contact Information

If you have any questions or comments about this notice, the ways in which Alpha 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 us by phone, postal mail, or email as noted below:

40 Wall Street, Suite 2806

New York, NY 10005

+1 (212) 933-9301

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Changes to Our Privacy Policy
We reserve the right to change our privacy policy in the future, but we will not disclose your non-public personal information except to our affiliates and as otherwise required or permitted by law without giving you an opportunity to instruct us not to.

If you have questions regarding these policies, please contact us by writing to Alpha RIA LLC, 40 Wall Street, 28th Floor, New York, New York 10005, Attention: Chief Compliance Officer, emailing or by calling +1 (212) 933-9301. Your privacy is very important to us. These policies apply to our clients and may be changed at any time, provided a notice of such change is given to you.

This policy composes a part of our Form ADV Part 2A, which is available at and upon emailed request to This version is reproduced here for your convenience.

GDPR Privacy Policy Notice

Effective January 1, 2022

Our Commitment to Protect your Privacy

Alpha maintains physical, electronic, and procedural safeguards that comply with federal standards such as the Gramm-Leach-Bliley Act (GLBA) and the European Union’s (EU) General Data Protection Regulation (GDPR) to protect its clients’ nonpublic personal information (Personal Information) as defined under GLBA, and to the extent applicable, “personal data” as defined under the GDPR. For the purposes of this policy, “personal data” means information that can directly or indirectly, identify an individual person and specifically includes, but is not limited to, a client’s name, address, birthdate, social security number, bank account number(s), tax identification number, other government-issued identification numbers; other forms and documents a client sends to us; and any other information about a client’s transactions with us.

This policy shall also include “Personal Data” that we collect on our firm’s website (Site), such as cookies. Through this policy and its underlying procedures, Alpha attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

You can find out more about Alpha at our Site or by contacting us using the information in the ‘contact us’ section.

How and What Type of Personal Information We Collect

To conduct regular business, Alpha may collect personal information from sources such as:

  • Personal Information reported by the client on applications or other forms the client provides to the firm
  • Personal Information about the client’s transactions implemented by the firm or others
  • Personal Information developed as part of financial plans, analyses or investment advisory services
  • Personal Information collected on our Site such as cookies.

To administer, manage, service, and provide related services for client accounts, it is necessary for Alpha to provide access to customer information within the firm and to nonaffiliated companies, with whom the firm has entered into agreements with.  To provide the utmost service, the firm may disclose the information below regarding customers and former customers, as necessary, to companies to perform certain services on the firm’s behalf.

  • Information Alpha receives from the client on applications (name, social security number, address, assets, etc.), from third parties authorized to share your information with us, from Cookies, or from publicly available information
  • Information about the client’s transactions with the firm or others (account information, payment history, parties to transactions, etc.)
  • Information concerning investment advisory account transactions
  • Information about a client’s financial products and services transaction with Alpha

In addition to the above, other specific types of Personal Information that Alpha collects includes, but is not limited to: birthdate, bank account number(s), tax identification number, other government-issued identification numbers; other forms and documents a client sends to Alpha, as well as information to create a client’s online account.

How We Use Your Personal Information

Alpha will only use your Personal Information for the purpose of providing investment advisory services to you, including, but not limited to: (1) to monitor, audit, evaluate and otherwise administer our services; (2) to communicate with you; (3) in an effort to protect against fraud and identity theft; (4) comply with applicable legal requirements, relevant industry standards, contractual obligations, and our policies and terms; and (5) for other purposes as required or authorized by law, including other purposes for which you have provided your consent and our legitimate interests.

Lawful Basis to Process Your Personal Information

To lawfully process your Personal Information, Alpha retains one or more of the following lawful bases: (1) your voluntary consent in connection to providing you with Alpha’s investment services; (2) as necessary in order to fulfill certain contractual obligations; (3) as necessary to comply with applicable rules, laws, and regulations; and (4) as necessary in connection to the legitimate interests of our firm and/or a third party.

Your Rights and Limits on Sharing

In terms of your rights, to the extent permitted by applicable law, you may request: (1) to have your Personal Information corrected; (2) to opt out of receiving marketing communications at any time; (3) to file a complaint with an applicable government regulator; (4) to access the Personal Information Alpha holds about you; (5) to restrict or object to the processing of your Personal Information, or request that your Personal Information is erased; (6) to receive a copy of the Personal Information you have provided to Alpha, in a structured, commonly used format (known as “data portability”); (7) have a copy of your Personal Information provided to you or another controller where technically feasible; (8) to withdraw your consent to Personal Information that you provided to us voluntarily, or otherwise consented to its use.

To the extent U.S. Federal laws apply to your Personal Information, you have the right to limit only: (i) sharing for affiliates’ everyday business purposes; (ii) affiliates from using your Personal Information to market to you; and (iii) sharing for non-affiliates to market to you. U.S. state laws and individual companies may give you additional rights to limit sharing.

Alpha may share your Personal Information for its everyday business purposes such as maintaining your account(s) or responding to court orders and legal investigations. For these types of purposes, you cannot limit sharing. We do not use your Personal Information to market our services to you. Moreover, Alpha does not share your Personal Information with “non-affiliated” companies for marketing purposes or for “joint marketing” purposes as those terms are defined under applicable U.S. Federal law.

As discussed above, we will endeavor to ensure your Personal Information is kept accurate, complete, up to date, and relevant. Please let us know if any of your details change. If you feel your Personal Information is not accurate, complete, or up to date, please notify us and we will take reasonable steps to ensure it is corrected. Additionally, you have the right to know what kind of information we collect and retain about you, to have reasonable access to it, and to request a copy of it. You can contact us to request this information using the details listed below.

In accordance with the foregoing, Alpha may take steps to verify your identity before granting you access to your Personal Information.

How We May Share Your Personal Information with Third Parties

Since Alpha shares non-public information solely to service client accounts, the firm does not disclose any non-public Personal Information about the firm’s customers or former customers to anyone, except as permitted by law, such as to government entities, or other third parties in response to subpoenas. In the event that the firm has a change to its customer privacy policy that would allow it to disclose non-public information not covered under applicable law, the firm will allow its clients the opportunity to opt out of such disclosure.

How Long We Retain Your Personal Information

To the extent permitted by applicable law, Alpha retains your Personal Information for the period necessary to serve the purposes for which Alpha obtained it. Alpha may also retain your Personal Information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.

How We Maintain Accuracy of Your Personal Information

Alpha will endeavor to ensure your Personal Information is kept accurate, complete, up to date, and relevant. Please let Alpha know if any of your details change. If you feel your Personal Information is not accurate, complete, or up to date, please notify us and we will take reasonable steps to ensure it is corrected. You can contact us in the Contact Us section below.

Former Clients

Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you and we will continue to treat your non-public information with strict confidentiality.

Data Controller

To the extent GDPR applies, Alpha is the data controller for this policy located at the address below.

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Additional Personal Information about Our Site

For additional information about our Site policies, please refer to the section of this Site titled Terms or Terms & Conditions.

Changes to this Policy

Alpha will provide each client with initial notice of the firm’s current policy when the client relationship is established. Alpha shall also provide each client with a new notice of the firm’s current privacy policies at least annually. If, at any time, Alpha adopts material changes to its privacy policies then the firm shall provide each client with a revised notice reflecting the new privacy policies.

U.S. Consumer Privacy Policy

Individual consumers who are customers or former customers of Alpha, please refer to the Alpha Privacy Policy. The privacy policies describe the information collected, with whom the information is shared, and how the information is protected and safeguarded.

Contact Us

Should you have any questions regarding the above, please contact:

Alpha RIA LLC, Attention: Chief Compliance Officer

40 Wall Street, 28th Floor

New York, NY 10005

+1 (212) 933-9301