Disclaimer & Privacy Policy

Disclaimers

Leo Wealth (the “Company” and with its subsidiaries the “Group”), a Delaware corporation conducts business through individual entities that are licensed (where applicable) in different jurisdictions for different businesses. Not all services are available in all markets in which the Group operates. None of the companies in the Group offer legal advice. Clients of the Group should refer to their written agreements with a Group company for further details.

In the United States, securities are offered through Leo Brokerage LLC, Member FINRA/MSRB.

Investment Advisory services are offered through Leo Brokerage LLC, Leo Wealth LLC, and Leo Fund Services LLC. In Hong Kong investment advisory services are offered through Leo Capital Corp (Hong Kong) Limited.

Inside the United States, representatives may only conduct business with residents of the states and jurisdictions in which they are properly registered. Therefore, a response to a request for information may be delayed until appropriate registration is obtained or exemption from registration is determined. Not all services referenced are available in every state and through every advisor listed. For additional information, please contact the Company.

LeoGroup Tax Services LLC, also known as Leo Tax and Consulting LLC and provides tax, CFO and financial consulting services which are separate from the services offered through other Group companies. Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any US federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein.

SEC Rule 3a-4: Need for current information: In order to provide effective management of your account, it is important that we have current information regarding your financial status and circumstances. Please contact us in writing at the physical address or email address above if you have any changes in your financial situation or investment objectives, and whether you wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions.

In Hong Kong, Leo Capital Corp (Hong Kong) Limited, CE. No BIH055, is licensed and authorized by the Securities and Futures Commission (“SFC”) to engage in advising on securities and asset management. These services will be governed by the terms of the Company’s Client Management Agreement (“CMA”) in force from time to time.

With respect to all members of the Group, content provided by us to clients and potential clients directly or via our website (“Group Content”) have not been reviewed or authorised by the SFC, SEC or any other regulator or government authority. Investment involves risks, including the loss of principal. Past performance is not an indication of future performance.

The Group Content does not constitute any investment advice and investors are advised to consider their own investment objectives and circumstances in determining the suitability of an investment in any investment product or portfolio management service. If you are in any doubt, you should seek professional advice, including tax and legal advice. Investors should refer to any relevant prospectus for further details, including product features, risk factors and restrictions on owning and holding a portfolio or the underlying funds and ETFs that compose a portfolio.

The historical track record, performance, and related calculations shown in the Group Contents and related materials are provided to show you how client accounts have performed in strategies managed by the firm and its partners. The Group manages investment strategies and may at some future date offer investment funds or other investment products to access these strategies. Please read performance related materials carefully and ensure all material queries are answered to your satisfaction prior to investing.

The Group is not registered or authorized to provide financial services in other jurisdictions not specified above. If you require investment or insurance services in these jurisdictions, will refer you to companies with whom we are acquainted in those jurisdictions. For the People’s Republic of China (the “PRC”), the information contained in Group Content does not constitute a public offer of any investment products in the PRC. No investment service or portfolio is being offered or sold directly or indirectly in the PRC to the PRC public. Further, no legal or natural persons of the PRC may directly or indirectly purchase any investment portfolios or any beneficial interest therein without obtaining all prior governmental approvals that are required by the PRC (which includes conducting due approval or registration or filing formalities under the PRC laws), whether statutorily or otherwise. Persons who come into possession of Group Content are required to observe these restrictions.

In Japan, none of the entities in the Group are licensed or registered for any businesses regulated by Japanese statutes and regulations including, without limitation, broker/dealer services or investment management or advisory services concerning securities, commodities, or other financial instruments or derivatives related thereto, insurance brokerage or agency services, or services concerning preparation of Japanese tax returns.

Group Content is provided for discussion purposes only and is not an offer to sell or the solicitation of an offer to buy securities, insurance or other financial products, or any recommendation to buy or sell, or any valuation of, any particular securities or other financial instruments. The Group Content is for distribution only to potential investors who are authorized to receive them and, in a jurisdiction, where the Group is authorized to do business. No offer to sell (or solicitation of an offer to buy) will be made in any jurisdiction in which such offer or solicitation would be unlawful. Group Content is not, nor is it intended to constitute, an advertisement or expected performance of any investment product and is no guarantee of future returns. Group Content is not intended for public use or distribution. The information in Group Content was developed using both publicly available and proprietary data that we assumed to be accurate; nevertheless, we accept no liability and offer no guarantee as to its being correct at any time and explicitly disclaim any responsibility arising therefrom. The Group Content can be changed without prior notice. The Group expressly disclaims all liability for representations, expressed or implied, contained in, or omissions from the Group Content. In addition, certain of the information contained in Group Content has been obtained from sources outside of the Group. No part of Group Content may be reproduced or shared without the permission of a member of the Group. Please contact the Group with any questions.

Privacy Policy

The Leo Capital Corp Group (“Leo Wealth” or the “Group”) includes a variety of entities who can assist you in different ways. In the US the Group referred to herein as ”Leo Wealth” or “Leo” includes Leo Wealth LLC, Leo Fund Services LLC, and BFT Financial Group LLC (pending name change to Leo Brokerage LLC), an SEC Registered Broker Dealer/Investment Adviser and FINRA Member Broker Dealer. In Hong Kong, the Group includes an SFC Licensed Corporation CE No. BIH055 for Advising on Securities (RA4) and Asset Management (RA9) and an Insurance Authority Company, License Number FB1205. In the US, brokerage and investment management services and fees differ, it is important for the retail investor to understand the differences. Free and simple tools are available to research firms and financial professionals at Investor.gov/CRS, which provides educational materials about broker-dealers, investment advisers, and investing. Please also see the discloses attached at the back of this document.

We Take Privacy Seriously

Leo Wealth has adopted policies regarding privacy and data protection in accordance with local regulations. We recognize that protecting the privacy and security of the non-public personal information we obtain about our clients is an important responsibility, as is the delivery of personalized, suitable advice. To deliver high quality, personalized services to you, we must collect and maintain certain non-public personal information about you. We want you to know what information we collect and how we use and safeguard that information. For a copy of our current privacy policy, please contact your advisor or call your local office.

What Information We Collect

We collect certain non-public personal information about you (such as your name, address, social security number, passport, etc.) that you provide on applications or other forms as well as communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.). We also collect information about your investments and brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.). Accurate information in critical to us providing you accurate advice and recommendations. As your needs and circumstances change, please contact your advisor immediately to update this information. We can serve you best by fully understanding you and you situation.

What Information We Disclose

We do not disclose the non-public personal information we collect about our clients to anyone except: (1) in furtherance of our business relationship with clients, and then only to those persons necessary to effect the transactions and provide the services that clients authorize (such as broker-dealers, custodians, independent managers etc.); (2) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (3) our group Companies, attorneys, accountants, and auditors; or (4) as otherwise provided by law. We are permitted by law to disclose the non-public personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative services on our behalf). These third parties are prohibited to use or share the information for any other purpose. If you decide to either terminate our services or become an inactive client, we will continue to adhere to our Privacy Policy, as may be amended from time to time. We are required to report any suspected exploitation of vulnerable adult clients to the proper authorities under federal and state statutes.

Security of Your Information

We restrict access to your non-public personal information to those Group companies and employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your non-public personal information.

Changes to Our Privacy Policy or Relationship With You

Our policy about obtaining and disclosing information may change from time to time. We will provide you notice of any material change to this policy before we implement the change. We will make notifications in writing by email or written correspondence. You content to receiving updates via email.

Opting Out

Clients cannot opt out of allowing us to share their non-public personal information with non-affiliated third parties such as custodians, insurance companies and technology service providers which are necessary to service their accounts.

Hong Kong Personal Data Privacy Ordinance Compliance

In addition, in Hong Kong, our policy on Data Collection is designed to conform to the standards laid down by Hong Kong’s Personal Data (Privacy) Ordinance. Leo Capital Hong Kong Limited and Leo Protection Hong Kong Limited (together the “Hong Kong Companies”) have the following policy in regard to use of Personal Data:

  • This policy is being provided to existing and prospective individual clients of the Hong Kong Companies from whom personal information has been and/or may in the future be collected. Personal information collected from the client (the data) by the Investment Adviser may be used for the purposes of providing investment advisory and management services, direct marketing, and compiling statistics for internal use. We will observe the Ordinance in the collection, maintenance and the use of Data. In particular we will ensure only legitimate means are used to collect Data, the Data used is accurate as possible, the use of the Data is consistent with the Personal Data (Privacy) Ordinance (Cap 486) in Hong Kong and the contractual obligations of the Hong Kong Companies, and the Data is protected and made available only to the authorized persons.
  • Clients have the right to inspect and amend Data any time. Data will only be disclosed consistent with the contractual rights and obligations of the investment adviser to other parties or to other parties authorized by law to receive it. All your personal information held by the Company will be used and disclosed in accordance with the Company Privacy Policy available on request. The client has the right to check whether the Company holds Data about the Client and gain access to such Data, require the Company to correct any inaccurate Data to the Client and ascertain the Company’s policies and practices in relation to Data and be informed of the kind of Data held by the Company.

REQUESTS FOR INFORMATION

For a copy of our Privacy Policy, please contact the Chief Compliance Officer either in writing at 860 Airport Freeway, Suite 402, Hurst, Texas 76054, or by phone at (817) 354-1090. For a copy of our Hong Kong privacy policy, please contact the Compliance Officer either in writing at 8F On Building, 162 Queens Road Central, Central, or by phone at +852 3468 8880. This is our current policy effective July 2021 for all Companies in the Leo Capital Corp group.

California Privacy Policy Notification

Leo Wealth’s California Privacy Notice supplements the information contained in Leo Wealth’s other privacy policies and practices 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, investment advice, insurance services, tax and consulting services, financial planning services, estate planning and wealth management consulting (collectively, “Services”). We provide 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 herein. This notice does not apply to Leo Wealth’s clients outside the United States, where other local statutes and ordinances may apply. If you have any questions or comments about this notice, the ways in which Leo Wealth 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 your local office or our COO Stephen Tally at +1-817-354-1090.

Changes to our Notices and Policies

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 to be aware of any modifications. If you do not agree 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.

Security

Leo Wealth maintains cyber security policies and practices and provides regular training to employees on these policies. 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 Leo Wealth’s privacy policies.

Categories and Details of Information We Collect

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, Leo Wealth’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.)
  3. Protected classification characteristics under California or federal law: Leo Wealth 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.

  1. 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.
  2. Geolocation data, Internet or other similar network activity: IP address, Cookie data and other similar activity concerning an interaction with our Services.
  3. Work/employment-related information: career industry, employer information, years in industry or with current employer, job applications, and any information provided in a resume/CV or employment seeker profile (including, but not limited to, executive summary, objective, current or prior work experience and education).

However, please note that Leo Wealth has not collected any of the following categories of personal information from consumers within the last twelve (12) months and does not intend to collect such data in the future:

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

a. Non-Personal Information

Leo Wealth uses de-identified and/or aggregated consumer information, which is not considered personal information. Deidentified 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. We also don’t use information or extensions drawn from other personal information to create a profile or record on you.

b. Sources of Personal Information

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

  • Information coming 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.
  • Information coming indirectly from you. For example, through automated technologies or your interactions with us, including from observing your actions when you use our Website.
  • Information from 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).

Use Of Your 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.

Leo Wealth 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.

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 Leo Wealth 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 relationships or you may have engaged with a third party mutually. 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.


a. 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, Leo Wealth 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:


• Various service providers that we use to support our business, provide services to us, and/or help provide our services to you. Other 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 IRD, HMRC, 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 Leo Wealth, 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 Leo Wealth, 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.


b. Sale of Personal Information


Your privacy is our priority, and we do not monetize your personal information by selling it to third parties.


Contacting Us


If you have any questions or comments about this notice, the ways in which Leo Wealth 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 your local office or our COO Stephen Tally at +1-817-354-1090.


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.


Access to Specific Information and Data Portability Requests


You may request that Leo Wealth 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.


a. Requests to Delete Information


You may request that Leo Wealth delete any or all of your personal information that we collected from you and retained, subject to certain exceptions and limitations under applicable laws. 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 or regulatory obligation; and/or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.


b. 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:
• Call +1-817-354-1090 and confirm 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 Wealth Manager. 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.


c. Response Timing and Format of Data


We work to respond to a verifiable consumer request within forty-five 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 JSON file format. You may request a particular format and will consider it. We generally do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If for any reason we determine that the request made by you warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


d. Opting Out from the Sale of Personal Information


We do not and do not intend in the future to 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”.


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


Leo Wealth as a Service Provider


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


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


Where Leo Wealth 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. If you have questions about this, please contact us. If you have any questions or comments about this notice, the ways in which Leo Wealth 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 your local office or our COO Stephen Tally at +1-817-354-1090.

GDPR and GLBA Notification

The Leo Wealth group of companies, including all of the entities owned by Leo Capital Corp, (also the “group” “we,” “us,” or “our”) 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’ non-public 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. Not all policies will apply to all clients based on their geographic location and other factors. To the extent GDPR applies, Leo Capital Corp and the group are the data controller for this policy located at our office in Hurst, Texas as noted on our website. If you have any questions regarding the above, please contact any of our office or our COO Stephen Tally at +1-817-354-1090.

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, we attempt 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. US residents should refer to our US privacy policy. California residents should also see our California Privacy Policy. Hong Kong residents should refer to their rights under the Hong Kong Personal Privacy Ordinance. If you have any questions regarding the above, please contact any of our office or our COO Stephen Tally at +1-817-354-1090, located in our office in Hurst, Texas.

Changes to this Policy

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


Personal Information We Collect


To conduct regular business, Leo Wealth 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 website such as cookies.


To administer, manage, service, and provide related services for client accounts, it is necessary for Leo Wealth to provide access to customer information within the firm and to unaffiliated companies, with whom the firm has entered into agreements with. For example, we will share information with your chosen custodian when setting up your investment advisory accounts. To provide the best and most complete 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 Leo Wealth 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 your accounts and the investment advisory account transactions
• Information about a client’s financial products and services transaction with Leo Wealth, including tax, estate and insurance services


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


How We Use Your Personal Information


Leo Wealth 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.


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 Leo Wealth holds about you; (5) to restrict or object to the processing of your Personal Do Not Track Signals Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across Sites or online services. We do not track users across time or over multiple websites, we do not receive, or respond to, browser do-not-track signals or other similar mechanisms. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. We cannot guarantee the policies or practices of third party sites. Information, or request that your Personal Information is erased; (6) to receive a copy of the Personal Information you have provided to Leo Wealth, 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 nonaffiliates to market to you. U.S. state laws and individual companies may give you additional rights to limit sharing. Leo Wealth 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 tomarket our services to you. Moreover, Leo Wealth 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 endeavour 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, Leo Wealth may take steps to verify your identity before granting you access to your Personal Information.


Lawful Basis to Process Your Personal Information


To lawfully process your Personal Information, Leo Wealth retains one or more of the following lawful bases: (1) your voluntary consent in connection to providing you with Leo Wealth’s investment services; (2) as necessary to fulfil 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.


Security


As our Site is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of Personal Information you communicate to us online. We also cannot guarantee that the Personal Information you supply will not be intercepted while being transmitted over the internet. Accordingly, any Personal Information or other information which you transmit to us online is at your own risk. We recommend you send data to us in a secure manner and can provide a secure link for data uploads upon request.


How We Share Your Personal Information with Third Parties


Since Leo Wealth 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, consumer reporting agencies or other third parties in response to subpoenas. If 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. We do not and do not intend to ever sell or otherwise trade client data.


Third-Party Websites and Links


As a convenience to you, Leo Wealth may provide hyperlinks to websites operated by third parties. When you select these hyperlinks, you will be leaving our website. However, we have no control over third party websites, their content, or security. Therefore, when you access these third-party websites, it is at your own risk. We encourage you to read the associated privacy policies by such third-party websites to learn more about their separate data privacy management practices. Third parties may have policies that differ significantly from our own.

How Long We Retain Your Personal Information


To the extent permitted by applicable law, Leo Wealth retains your Personal Information for the period necessary to serve the purposes for which Leo Wealth obtained it. Leo Wealth 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. Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you as a former client and we will continue to treat your non-public information with strict confidentiality and will conform with applicable laws and regulations.


How We Ensure Accuracy of Your Personal Information


Leo Wealth will work to ensure your Personal Information is kept accurate, complete, up to date and relevant. Please let Leo Wealth 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.


Cookies


We may use “cookies” to help us tailor our Site to better suit your needs (for example, we may use cookies to enable us to save any personal preferences indicated by you) and to provide a more effective route to various components of our Site. You may request a copy of our Cookie policy at any time. If you have any questions regarding the above, please contact any of our office or our COO Stephen Tally at +1-817-354-1090.


Site Developed for Adults Only


Our website and materials are not directed to children under the age of 18 years. By using our Site, you represent and warrant that you are at least 18 years old. We respect the privacy of children and do not knowingly collect or retain personally identifiable information or “Personal Data” from children under the age of 18 through this web site. However, we may process personal data, on a child’s behalf, with permission from the parent or guardian. To the extent we have unintentionally collected any Personal Data on our Site from a person under the age of 18 years old, you may request and obtain removal of this Personal Data. To make such a request, please send an email with a detailed description of the specific content or information to the e-mail address below. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.


If you have any questions or comments about this notice, the ways in which Leo Wealth collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights please contact your local office or our COO Stephen Tally at +1-817-354-1090.

Use of Cookies Policy


A “cookie” is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do several things, e.g., remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website. This Cookie Policy describes how Leo Wealth and the Leo Capital Corp group. (Referred to herein as ““our,” “us,” or “we”) collects and uses cookies about you through our website (“Site”). If you have any questions or comments about this policy, please contact your local office or our COO Stephen Tally at +1-817-354-1090.

We use cookies on this Site for the commercial purposes set-forth below.

  • Functionality: Functional purpose cookies store information that is needed by our applications to operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, to facilitate completion of the overall transaction or request.
  • Analytics: Analytical cookies allow us to recognize, measure and track visitors to our Site. This helps us to improve and develop the way our Site works by determining whether Site visitors can find information easily, or by identifying the aspects of the Site that are of the most interest to them.
  • User preferences: Some of the cookies on our Site may be activated when visitors to our Site make a choice about their usage of the Site. Our Site remembers the settings preferences of the user concerned. This allows us to tailor aspects of the Site to the individual user.
  • Policies, terms, and conditions: We may use cookies on our Site to record when a Site visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and conditions on our Site. This helps to improve the user’s experience of our Site – for example, it avoids a user from repeatedly being asked to consent to the same terms or policies, improving the user experience.
  • Session management: This type of cookie helps the website track internet usage. Session cookies are temporary and are deleted from your machine when your web browser closes.
  • Third-party cookies: When you visit our Site, you may receive cookies that are set by third parties. These cookies are used for the purposes described in the bullet points above. We do not control the setting of these third-party cookies, so we suggest you might wish to check the third-party websites for more information about their use of cookies and how to manage them.


Your Consent

By continuing to use our Site, you are agreeing to our placing cookies on your computer to analyze the way you use our Site. Please read this Cookie Policy carefully for more details about the information we collect when you use our Site. If you do not wish to accept cookies in connection with your use of this Site, you must stop using our Site or manually adjust your Cookie settings in your browser. This is an example set of instructions provided by Google for clearing or changing the Cookie settings inside the Chrome browser:https://support.google.com/chrome/answer/95647?hl=en&co=GENIE.Platform%3DDesktop

Control Cookies through Browser Controls:
You can use your web browser to delete all cookies, block all cookies, allow all cookies, block third-party cookies, clear all cookies when you close the browser, open a ‘private browsing’ / ‘incognito’ session, which allows you to browse the internet without storing local data; and install add-ons and plug-ins to extend browser functionality.

You may obtain more information on Cookies here:
https://www.cloudflare.com/learning/privacy/what-are-cookies/.

If you have any questions or comments about this policy, please contact your local office or our COO Stephen Tally at +1-817-354-1090.

Japan Personal Information Protection Policy

Each of us, Leo Wealth Japan KK, whose mailing address is Level 20, Marunouchi Trust Tower-Main, 1-8-3 Marunouchi, Chiyoda-ku, Tokyo, Japan 100-0005, Leo Tax and Consulting LLC, whose mailing address is 100 Wood Avenue South, Suite 209, Iselin, NJ 08830, and Leo Capital Corp (Hong Kong) Limited, whose mailing address is 8/F, On Building, 162 Queen’s Road Central, Hong Kong, recognizes that it is our important responsibility to protect and utilize our customers’ personal information appropriately. We therefore implement the following policies to protect personal information. We will acquire personal information of our customers (including prospective customers: “Clients”) and their family members, in order to provide Clients with our (“Services”), which will be outlined in additional details in the Engagement Letter entered into with or proposed to respective Clients. We will ask Clients to provide us various documents, materials and information which contain personal information of the Clients and their family members.


Our purposes and use of the personal information are as follows:


1. To introduce and propose Services to Clients and/or their family members which may be suitable to the Clients and/or their family members;
2. To complete U.S. tax return documents and related tax compliance materials on Clients’ behalf;
3. To improve the quality of the Services we provide to Clients;
4. To provide Services and to perform obligations under contracts which Leo Wealth Japan KK, Leo Tax and Consulting LLC, and/or other Leo Wealth entities enter into with Clients or their family members in connection with Services;
5. To contact Clients and/or their family members in connection with the above;
6. To deliver promotional materials concerning other services similar to Services and;
7. To help ensure the advice and information concerning Services is suitable to Clients’ needs.


We may inform Clients and/or their family members of any additional purposes when we receive from Clients and/or Clients’ family members additional documents, materials or information which may contain personal information.


We will comply with laws and regulations applicable to treatment of personal information of our Clients and their families. We will publish or notify to our Clients and their family members the purpose of use of the personal information on them acquired by us unless otherwise permitted under the applicable laws and regulations.


We will not make the personal data on our Clients and their family members available to third parties unless permitted by applicable laws without consent of the relevant Clients and their family members. We may request the Clients and their family members to upload their personal information which we need in providing the Services onto certain cloud account designated by us, to which each of us has access. The information uploaded onto such cloud account by the Clients or their family members are deemed as provided to each of us. If you wish us to suspend access to such designated cloud account by any of us, please contact Leo Wealth Japan KK. Please note that, if access to the designated cloud account by any one of us is suspended at your request, we may have to refrain from providing such portion of the Services that cannot be provided without sharing such information. We may share and jointly use the personal information received from, and/or other personal data acquired by Leo Tax and Consulting LLC during the course of providing the Services concerning, Clients and/or their family members, with Leo Wealth Japan KK. We may need additional and separate consent of the relevant Client and/or his/her family members to share their personal information and/or data with entities located outside Japan during the course of providing the Services. In such event, we may request such Client and/or his/her family members directly to provide the relevant personal information and/or data to such entities located outside Japan.


The particulars concerning such sharing and joint use are as follows:
1. Items of personal information/data to be shared and jointly used:
Name
Address
Phone number
Facsimile number
E-mail address
Copies of documents filed with Federal or state tax authorities and supporting documents underlying such filed documents.
Items to be notified by us to respective Client and his/her family members whose personal information/data will be shared/jointly used before such items of personal information/data are actually shared.
2. Persons/entities with whom the personal information/data acquired by Leo Tax and Consulting LLC or Leo Capital Corp (Hong Kong) Limited may be shared and jointly used:
Leo Wealth Japan KK Persons/entities to be notified by us to respective Client and his/her family members whose personal information/data will be shared/jointly used before such items of personal information/data are actually shared.
3. Purposes of use of the personal information/data by the persons/entities with whom the personal information/data may be shared and jointly used:
The purposes and use of the personal information set forth in the above, and/or other purposes which to be notified by us to respective Client and his/her family members whose personal information/data will be shared/jointly used before such items of personal information/data are actually shared
4. Person/entity which is responsible for the administration of the personal information/data to be
shared:


Leo Wealth Japan KK
If you wish to limit the use of your personal information or have questions concerning the sharing/joint use of personal information/data, please contact us at Leo Wealth Japan KK or email us at connect@leowealth.com.