Privacy Policy

Intentional Asset Management LLC
Last Updated: December 20, 2025

Intentional Asset Management LLC (“Intentional Asset Management,” “Company,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you visit our website at https://intentionalam.com (the “Site”) and any related online services on which this Privacy Policy is displayed (collectively, the “Services”).

This Privacy Policy applies whether you visit the Site for informational or educational purposes, communicate with us, or otherwise interact with us through the Services. This Privacy Policy is incorporated into and subject to our Terms of Use.

Privacy Policy Summary

Intentional Asset Management collects limited personal information when individuals visit our website or communicate with us, including contact information and other information voluntarily provided. This information is used to respond to inquiries, provide information about our firm and services, improve our website, and operate our business. We do not collect brokerage login credentials through the website, do not sell personal information, and do not use automated decision-making to provide investment advice. Personal information is safeguarded using reasonable measures and is shared only with service providers, affiliates, or third parties as permitted or required by law.

1. Contact Us

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

Intentional Asset Management
12 East 49th Street, 11th Floor
New York, NY 10017
Email: Info@IntentionalFunds.com

2. Scope of This Policy

This Privacy Policy describes data collected through the Site and Services. It does not address privacy practices for third-party websites or services that may be linked from the Site.

We do not provide a client portal through the Site and do not request or collect financial institution usernames or passwords through the Site.

3. Information We Collect

We collect information in three primary ways: (A) information you provide, (B) information collected automatically, and (C) information from third parties.

A. Information You Provide to Us

Depending on how you interact with the Site, we may collect the following categories of personal information that you voluntarily submit:

  • Identifiers and contact information: name, email address, telephone number, mailing address

  • Professional information: job title, employer/company name

  • Communications: the content of messages you send to us (e.g., inquiries, requests, or feedback), and any attachments or information you choose to provide

  • Survey or form responses: information you submit through online forms or surveys (if any), including general preferences or interests

Important: Please do not submit sensitive personal information (e.g., Social Security numbers, account login credentials, precise account numbers, medical information) through the Site unless we specifically request it through a secure process and you intend to provide it.

B. Information Collected Automatically

When you visit the Site, we and our service providers may automatically collect certain information, including:

  • Device and connection information: IP address, device type, operating system, browser type, language settings

  • Approximate location: general location inferred from IP address (e.g., city/state)

  • Usage data: pages visited, time spent on pages, referring/exit pages, links clicked, and other browsing activity on the Site

This information is collected via cookies and similar technologies (described further below).

C. Information From Third Parties

We may receive information about you from third parties in limited circumstances, such as:

  • Business contacts and referral sources who provide your contact information with your permission or in a professional context

  • Public sources (e.g., professional networking platforms or other publicly available information)

  • Service providers (e.g., marketing, analytics, or website vendors) that support Site operations

4. Cookies and Similar Technologies

We use cookies and similar technologies to operate the Site, understand how it is used, and improve performance.

A. Types of Cookies We May Use

  • Strictly necessary cookies to enable core functionality

  • Performance/analytics cookies to understand Site usage and improve the Site

  • Functionality cookies that remember preferences (where applicable)

B. Analytics

We may use third-party analytics services (such as Google Analytics) to help us understand how visitors use the Site. These services may collect information such as how often users visit the Site and what pages they view. We use this information to improve the Site and Services.

Google’s handling of information is governed by Google’s privacy practices.

C. Your Cookie Choices

You can manage cookies through your browser settings. If you disable cookies, some Site features may not function as intended.

5. How We Use Personal Information

We use personal information for the following purposes:

  • Provide and operate the Site: maintain functionality, diagnose issues, and support Site operations

  • Respond to you: reply to inquiries, provide requested information, and communicate about your requests

  • Business communications: send administrative messages and updates (e.g., policy updates)

  • Marketing and informational communications: send newsletters, event updates, or firm information where permitted by law and consistent with your choices

  • Improve and develop: analyze Site usage, conduct internal research, and improve our content and Services

  • Security and integrity: protect against fraud, abuse, and unauthorized activity

  • Legal and regulatory: comply with applicable laws, respond to lawful requests, and maintain records as required

We do not use personal information collected through the Site to conduct automated decision-making or profiling for investment recommendations.

6. How We Disclose Personal Information

We may disclose personal information in the following circumstances:

A. Service Providers

We may share personal information with vendors and service providers who support our operations (e.g., website hosting, IT support, analytics, email delivery). These providers are permitted to use personal information only to perform services for us and consistent with this Privacy Policy.

B. Affiliates

We may share personal information with entities under common ownership or control with Intentional Asset Management, subject to appropriate confidentiality and privacy protections.

C. Legal, Safety, and Rights Protection

We may disclose personal information if we believe disclosure is necessary to:

  • comply with law, regulation, or legal process

  • respond to lawful requests from public authorities

  • protect the rights, property, and safety of the Company, our users, or others

  • prevent or investigate suspected fraud, security issues, or policy violations

D. Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of some or all assets, personal information may be transferred as part of that transaction, subject to customary confidentiality protections.

We do not sell personal information. We also do not share personal information for cross-context behavioral advertising.

7. Data Retention

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

  • fulfill the purposes described in this Privacy Policy

  • meet legal, regulatory, accounting, or reporting requirements

  • resolve disputes and enforce agreements

  • maintain security and prevent fraud

Retention periods vary depending on the nature of the information and the purpose for which it was collected.

8. Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information. However, no security measure is perfect, and we cannot guarantee absolute security of information transmitted to or from the Site.

9. Your Choices and Rights

A. Marketing Emails

You may opt out of marketing or promotional emails by using the unsubscribe link in the email or by contacting us. Even if you opt out of marketing emails, we may still send non-promotional communications (e.g., responses to inquiries, policy updates).

B. Access, Correction, Deletion

You may request access to, correction of, or deletion of personal information we maintain about you by contacting us at Info@IntentionalFunds.com. We may need to verify your identity before responding and may retain certain information as required by law or for legitimate business purposes.

C. Browser Controls

You can control cookies through browser settings, as described above.

10. Children’s Privacy

The Site is not directed to individuals under 18, and we do not knowingly collect personal information from minors. If you believe a minor has provided personal information to us, please contact us so we can address it.

11. International Users

If you access the Site from outside the United States, you understand that your information may be processed and stored in the United States or other jurisdictions with different data protection laws. By using the Site and providing information to us, you consent to these transfers.

12. California Privacy Notice (CCPA/CPRA)

This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the CPRA, applies.

A. Categories of Personal Information We Collect

Depending on your interaction with the Site, we may collect the categories described above, which may include:

  • identifiers/contact information

  • internet or network activity information

  • professional information

  • communications content

B. Purposes of Collection

We use these categories for the purposes described in Section 5.

C. Sale/Share

We do not sell personal information and do not share personal information for cross-context behavioral advertising.

D. Your California Rights

Subject to applicable exceptions, California residents may have the right to:

  • Request disclosure of the categories and specific pieces of personal information collected

  • Request the deletion of personal information

  • Request correction of inaccurate personal information

  • Receive equal service and price, even if exercising privacy rights (non-discrimination)

To exercise these rights, contact us at Info@IntentionalFunds.com. We may verify your request and identity as permitted by law.

13. European/UK Users (GDPR/UK GDPR)

If you are located in the European Economic Area or the United Kingdom, the following applies:

  • Controller: Intentional Asset Management LLC is the controller of your personal information collected through the Site.

  • Legal bases: We process personal information as necessary for legitimate interests (e.g., operating and improving the Site, responding to inquiries), to comply with legal obligations, and with consent where required.

  • Your rights: You may have rights to access, correct, delete, restrict processing, object to processing, and data portability.

  • Cross-border transfers: Where personal information is transferred outside your jurisdiction, we use lawful safeguards such as standard contractual clauses or other mechanisms permitted by law.

To exercise rights, contact us at Info@IntentionalFunds.com. You also have the right to lodge a complaint with your local data protection authority.

14. Third-Party Links

The Site may link to third-party websites. We do not control and are not responsible for the privacy practices of third parties. Please review the privacy policies of any site you visit.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top reflects the effective date of the current version. Your continued use of the Site after changes become effective constitutes acceptance of the updated Privacy Policy.

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