Privacy Policy

PRIVACY POLICY

Effective Date: 2025-10-22

Operator: RichCo Asset Management, LLC, an Illinois limited liability company ("Company," "we," "our," or "us")

Last Updated: 2025-10-22

INTRODUCTION

This Privacy Policy explains how we collect, use, disclose, store, and protect information when you access or use this website (the "Site"). By using the Site, you consent to the data practices described in this Policy.

Please read this Policy carefully. If you do not agree with our practices, you must not use the Site.

1. INFORMATION WE COLLECT

We may collect the following categories of information:

A. VOLUNTARY INFORMATION (Information You Provide Directly)

Information you provide when you:

Subscribe to newsletters or email updates
Submit contact forms or inquiries
Create an account or user profile (if applicable)
Purchase products, services, or subscriptions
Submit comments, feedback, or user-generated content
Participate in surveys or promotional activities

This may include:

Name, email address, phone number
Payment information (processed securely through third-party payment processors)
Communication preferences
Any other information you choose to provide

B. AUTOMATICALLY COLLECTED INFORMATION (Technical and Usage Data)

When you visit the Site, we automatically collect certain technical and usage information, including:

IP address and approximate geographic location (city/region level)
Browser type, version, and language settings
Operating system and device information
Pages visited, time spent on pages, and navigation paths
Referral source (how you arrived at the Site)
Date and time stamps of visits
Clickstream data and interaction patterns

C. COOKIES AND TRACKING TECHNOLOGIES

We use cookies, web beacons, pixels, local storage, and similar technologies to:

Remember your preferences and settings
Analyze Site performance and user behavior
Provide security and prevent fraud
Deliver relevant content and functionality
Support analytics and advertising (see Section 1.D below)

You can control cookie settings through your browser, but disabling cookies may limit some Site functionality.

D. ANALYTICS AND ADVERTISING SERVICES

We use third-party analytics and advertising services, including but not limited to:

Google Analytics: Collects usage data to help us understand how visitors interact with the Site. Google Analytics may use cookies to track behavior across sessions and devices. For information about Google's data practices, visit: https://policies.google.com/technologies/partner-sites
Advertising Networks: We may display advertisements through third-party networks (such as Google AdSense). These networks may use cookies, web beacons, and similar technologies to:
- Deliver relevant advertisements
- Track ad performance and attribution
- Collect browsing behavior across websites
- Build advertising profiles

We do not control these third-party practices. Review their privacy policies for details on their data collection and use.

E. DO NOT TRACK SIGNALS

Our Site does not currently respond to "Do Not Track" (DNT) browser signals or similar mechanisms. You may control tracking through browser settings, cookie preferences, or third-party opt-out tools.

F. AI AND AUTOMATED PROCESSING NOTICE

We may use artificial intelligence (AI), machine learning (ML), and automated processing tools to:

Analyze user behavior and improve Site functionality
Generate, curate, or personalize content
Detect fraud, abuse, or security threats
Process and respond to user inquiries

These tools may process personal information as part of their operations. AI/ML systems may introduce errors, biases, or unintended outputs. We do not make solely automated decisions that produce legal or similarly significant effects without human oversight.

G. INFORMATION WE DO NOT INTENTIONALLY COLLECT

We do not intentionally collect:

Social Security numbers or government-issued ID numbers
Financial account credentials (passwords, PINs)
Sensitive health information or medical records
Biometric data (fingerprints, facial recognition)
Precise geolocation data (GPS coordinates)
Information from children under 13 years of age (see Section 9 below)

If such information is inadvertently collected, we will delete it upon discovery.

2. HOW WE USE INFORMATION

We use the information collected to:

Operate, maintain, secure, and improve the Site
Provide requested services, content, or communications
Process transactions and fulfill orders
Respond to inquiries, comments, and customer support requests
Send administrative communications (service updates, policy changes)
Analyze usage patterns and optimize user experience
Detect, prevent, and address fraud, abuse, security threats, and technical issues
Enforce our Terms of Use and other policies
Comply with legal obligations, regulatory requirements, and lawful requests
Conduct research, analytics, and statistical analysis (including AI/ML training)
Send marketing communications (where you have opted in or where permitted by law)

We do not sell, rent, or trade personal information to third parties for their marketing purposes.

We may share limited information in the following circumstances:

A. SERVICE PROVIDERS AND BUSINESS PARTNERS

We may share information with third-party service providers who perform functions on our behalf, including:

Cloud hosting and infrastructure providers
Payment processors and financial institutions
Email delivery and marketing platforms
Analytics and advertising services
Customer support and communication tools
Security and fraud prevention services

These providers are contractually obligated to protect your information and use it only for the purposes we specify.

B. LEGAL OBLIGATIONS AND SAFETY

We may disclose information when required or permitted by law, including to:

Comply with subpoenas, court orders, legal processes, or governmental requests
Enforce our Terms of Use, policies, or agreements
Investigate and prevent fraud, security threats, or illegal activity
Protect the rights, property, safety, or security of the Company, users, or the public
Respond to emergencies involving danger of death or serious physical injury

C. BUSINESS TRANSFERS

In connection with a merger, acquisition, reorganization, bankruptcy, sale of assets, or similar business transaction, personal information may be transferred to the acquiring or surviving entity. You will be notified of such transfers via email or prominent notice on the Site.

We may share information for other purposes with your explicit consent or at your direction.

E. AGGREGATED OR DE-IDENTIFIED DATA

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you. Such data is not subject to this Privacy Policy.

4. DATA RETENTION

We retain personal information only as long as reasonably necessary to:

Provide services and fulfill the purposes described in this Policy
Comply with legal, regulatory, tax, or accounting requirements
Resolve disputes, enforce agreements, and establish legal defenses
Maintain security, prevent fraud, and protect against abuse

Retention periods vary depending on:

The type of information and how it is used
Legal or regulatory requirements (some records must be retained for specific periods)
Whether you have requested deletion (subject to exemptions)

After the retention period expires, we will delete or anonymize personal information in accordance with applicable law and our data management policies.

5. USER RIGHTS AND REQUESTS

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

Access: Request a copy of the personal information we hold about you
Correction: Request correction of inaccurate or incomplete information
Deletion: Request deletion of your personal information (subject to legal exceptions)
Portability: Request your information in a structured, machine-readable format
Objection: Object to certain processing activities (such as marketing)
Restriction: Request limitation on how we process your information
Opt-Out: Unsubscribe from marketing emails or opt out of certain data uses

A. HOW TO SUBMIT REQUESTS

To exercise your rights, contact us at:

info@dividendideas.com

Requests must include:

Your full name and contact information
Description of the specific information or action requested
Sufficient detail to verify your identity
Statement of the legal basis for your request (if applicable)

B. RESPONSE TIMELINES

We will acknowledge receipt of requests within 60 days of submission.
We will complete processing within 180 days, unless shorter timelines are required by applicable law (such as GDPR's 30-day requirement or CCPA's 45-day requirement).
If we need additional time, we will notify you of the extension and the reasons for the delay.
Complex or voluminous requests may require additional time.

C. VERIFICATION AND LIMITATIONS

We will verify your identity before processing requests to protect against fraudulent or unauthorized requests.

We may deny requests that are:

Manifestly unfounded or excessive (including repetitive requests)
Prohibited or restricted by law
Likely to compromise the rights, privacy, or security of others
Require disclosure of confidential business information or trade secrets
Interfere with pending legal proceedings or investigations

We will provide written explanation for any denial or limitation.

D. APPEALS

If you are unsatisfied with our response, you may appeal by contacting us at the address above. Depending on your jurisdiction, you may also have the right to lodge a complaint with a data protection authority.

6. SECURITY

We employ commercially reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction.

Security measures include:

Encryption of data in transit and at rest (where appropriate)
Access controls and authentication requirements
Regular security assessments and vulnerability testing
Employee training on data protection and security practices
Incident response and breach notification procedures

However, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, and you use the Site at your own risk.

IF YOU BELIEVE YOUR INFORMATION HAS BEEN COMPROMISED, CONTACT US IMMEDIATELY AT info@dividendideas.com.

7. RESTRICTIONS ON DATA HARVESTING, SCRAPING, AND AUTOMATED ACCESS

To protect both users and the integrity of the Site, the following activities are strictly prohibited without prior written consent:

Scraping, crawling, or automated collection of any personal, technical, or content data from the Site
Use of bots, spiders, robots, or automated tools to access, extract, download, or index Site content or data
Framing, mirroring, or embedding any part of the Site on another website, application, or service
Deep-linking in a way that misrepresents affiliation, implies endorsement, or bypasses the Site's intended user experience or authentication
Aggregating, compiling, or creating derivative databases from Site data
Using Site content or data to train AI, machine learning, or language models without explicit written permission
Reverse engineering, decompiling, or otherwise attempting to derive source code, algorithms, or technical implementations

We actively monitor for such activities and reserve the right to:

Block IP addresses or user agents engaged in prohibited activities
Revoke any linking, access, or use permissions without notice
Pursue legal remedies, including injunctive relief and damages
Report violations to law enforcement or regulatory authorities

Authorized researchers, journalists, or academics seeking to access data for legitimate purposes must request written permission at info@dividendideas.com.

8. INTERNATIONAL USERS AND DATA TRANSFERS

The Site is operated from and hosted in the United States. If you access the Site from outside the United States, please be aware that:

Your information will be transferred to, processed, and stored in the United States
U.S. data protection laws may differ from those in your jurisdiction
By using the Site, you consent to the transfer and processing of your information in the United States

If you are located in the European Economic Area (EEA), United Kingdom (UK), Switzerland, or other jurisdictions with comprehensive data protection laws, additional protections may apply. Contact us for information about data transfer mechanisms and safeguards.

9. CHILDREN'S PRIVACY

This Site is not directed to, and we do not knowingly collect information from, children under 13 years of age (or the applicable age of digital consent in your jurisdiction).

If we discover that we have inadvertently collected information from a child under 13, we will promptly delete such information.
Parents or guardians who believe we may have collected information from a child should contact us immediately at info@dividendideas.com.
We do not sell products or services intended for purchase by children.

If you are under 13 (or the applicable age in your jurisdiction), do not use the Site or provide any personal information.

10. CHANGES TO THIS PRIVACY POLICY

We may revise, update, or modify this Privacy Policy from time to time to reflect:

Changes in our data practices or services
New legal, regulatory, or compliance requirements
Feedback from users or stakeholders
Technological developments or security enhancements

Updated versions will be posted on this page with a new "Last Updated" date.

Material changes will be highlighted at the top of the Policy or communicated via email (if we have your email address).
Your continued use of the Site after changes become effective constitutes acceptance of the revised Policy.
If you do not agree with changes, you must stop using the Site.

We encourage you to review this Policy periodically.

11. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide additional rights:

Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, purposes, and third parties with whom we share it.
Right to Delete: You may request deletion of your personal information (subject to legal exceptions).
Right to Opt-Out of Sale: We do not sell personal information as defined by CCPA. If our practices change, we will provide a "Do Not Sell My Personal Information" link.
Right to Correct: You may request correction of inaccurate personal information.
Right to Limit Use of Sensitive Personal Information: If we collect sensitive personal information as defined by CPRA, you may request limitation on its use.
Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.

To exercise California rights, contact us at info@dividendideas.com with "California Privacy Rights Request" in the subject line.

We will respond within 45 days (with possible 45-day extension if needed).

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, the General Data Protection Regulation (GDPR) or equivalent laws provide additional rights:

Legal Basis for Processing

We process your data based on:

Consent (where you have opted in)
Contractual necessity (to provide services you requested)
Legitimate interests (to operate, improve, and secure the Site)
Legal obligations (to comply with laws and regulations)

Enhanced Rights

Right of access and data portability
Right to rectification and erasure ("right to be forgotten")
Right to restrict processing or object to processing
Right to withdraw consent at any time
Right to lodge a complaint with your local data protection authority

Data Transfers

When transferring data outside the EEA/UK, we use standard contractual clauses or other approved mechanisms.

To exercise GDPR rights, contact us at info@dividendideas.com with "GDPR Request" in the subject line.

We will respond within 30 days as required by GDPR.

13. CONTACT INFORMATION AND DATA PROTECTION OFFICER

For questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us at:

RichCo Asset Management, LLC
Attn: Privacy Inquiry
info@dividendideas.com

ACKNOWLEDGMENT

By using this Site, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

END OF PRIVACY POLICY