Privacy Policy

1. Introduction

Aeternum Wealth Management ("we," "our," or "us") is committed to protecting the privacy and confidentiality of our clients' personal and financial information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website or engage our investment management services.

2. Information We Collect

Personal Information

We may collect the following types of personal information:

• Name, address, telephone number, and email address
• Date of birth and government-issued identification numbers
• Employment information and income details
• Investment experience and risk tolerance
• Bank account and financial institution information
• Investment objectives and financial goals

Financial Information

To provide our investment management services, we collect:

• Account balances and transaction history
• Investment holdings and performance data
• Tax identification numbers and tax-related information
• Credit information when relevant to our services

Technical Information

When you visit our website, we automatically collect:

• IP address and browser information
• Device type and operating system
• Pages visited and time spent on our website
• Referring website and search terms used

3. How We Use Your Information

We use your personal information for the following purposes:

• Providing investment management and advisory services
• Processing transactions and maintaining account records
• Conducting client suitability assessments
• Complying with legal and regulatory requirements
• Communicating with you about your account and our services
• Improving our services and website functionality
• Detecting and preventing fraud or unauthorized activities

4. Information Sharing and Disclosure

Service Providers

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

• Custody and clearing services (Interactive Brokers)
• Technology and data processing services
• Legal, accounting, and compliance services
• Marketing and communication services

Legal Requirements

We may disclose your information when required by law or regulation, including:

• Compliance with court orders or legal process
• Regulatory examinations and investigations
• Anti-money laundering and tax reporting requirements
• Protection of our rights and property

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

5. Data Security

We implement comprehensive security measures to protect your personal information:

• Encryption of data in transit and at rest
• Multi-factor authentication for account access
• Regular security assessments and updates
• Restricted access to personal information on a need-to-know basis
• Employee training on privacy and security protocols
• Secure disposal of physical and electronic records

6. Data Retention

We retain your personal information for as long as necessary to provide our services and comply with legal and regulatory requirements. Generally, we maintain client records for a minimum of seven years after account closure, or as required by applicable law. Some information may be retained longer for legal, regulatory, or business purposes.

7. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access to your personal information we hold
• Correction of inaccurate or incomplete information
• Deletion of your personal information (subject to legal requirements)
• Restriction of processing in certain circumstances
• Data portability where technically feasible
• Objection to certain types of processing

To exercise these rights, please contact us using the information provided in the "Contact Us" section below.

8. International Data Transfers

As a Vanuatu-based investment manager serving international clients, we may transfer your personal information across borders. We ensure that such transfers comply with applicable data protection laws and implement appropriate safeguards to protect your information during international transfers.

9. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to:

• Remember your preferences and settings
• Analyze website traffic and usage patterns
• Improve website functionality and user experience
• Provide personalized content and recommendations

You can control cookie settings through your browser preferences, though disabling cookies may affect website functionality.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website and updating the "Last updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.

12. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us: