Privacy Policy

Mercer Island Capital Management, LLC (MICap) Privacy Policy - 2024

Effective Date: March 12, 2025

1. Introduction

Mercer Island Capital Management, LLC ("we," "our," or "us") operates the website www.micap360-com.ghost.io ("Service"). This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information in compliance with Regulation S-P under the Gramm-Leach-Bliley Act (GLBA) to protect the privacy of our clients.

2. Definitions

Nonpublic Personal Information (NPI): Personally identifiable financial information not publicly available, such as Social Security numbers, account numbers, and transaction data. Service Providers: Third-party companies or individuals that assist in processing data or providing services on our behalf.

3. Information We Collect

We collect NPI in several ways:- Information provided by the client: Social Security numbers, account numbers, etc.- Third-party information: Such as credit reports. Transactional information: This includes account balances and transaction history.

4. Use of Collected Information

We use NPI to Provide and maintain services,- Respond to customer inquiries,- Fulfill legal obligations, and Improve our services.

5. Privacy Notices

We issue an initial and annual privacy notice to clients detailing Types of NPI collected,- How the information is used and shared, and Opt-out options for certain data-sharing practices.

6. Sharing Information with Affiliates and Nonaffiliates

We may share NPI with:- Affiliates and Service Providers: To fulfill business functions, while maintaining confidentiality agreements,- Nonaffiliated Third Parties: As required by law (e.g., to prevent fraud). Clients can opt out of nonessential NPI sharing with non-affiliates through instructions provided in our notices.

7. Security of Your Information (Safeguard Rule)

We have adopted policies to protect NPI, including physical and digital safeguards, employee training on secure data handling, Access controls, and incident response protocols.

8. Data Disposal

We securely dispose of NPI when no longer needed, following protocols for shredding paper records and securely deleting electronic data.

9. Changes to Our Privacy Policy

Clients will be notified of material changes to our Privacy Policy through updates on our website and annual notices.