legal


Privacy Policy

Most recently revised: September, 2026

1. Introduction

This Website Privacy Policy ("Policy") describes how IWP Op Co, LLC ("IWP Op Co, LLC," "we," "us," or "our") collects, uses, discloses, and protects personal information collected through our website located at [INSERT WEBSITE URL] (the "Site"). This Policy applies to visitors, prospective clients, job applicants, and others who interact with the Site.

This Policy is separate from, and does not replace, our privacy notice(s) provided to individual fund investors and clients under the Gramm-Leach-Bliley Act ("GLBA") and Regulation S-P, which govern nonpublic personal information collected in connection with an actual or prospective investment advisory or fund relationship. Where a conflict exists between this Policy and a GLBA-based investor privacy notice with respect to an existing investor's account information, the investor privacy notice controls.

2. Information We Collect

We may collect the following categories of information through the Site:

We do not knowingly collect nonpublic personal financial information (such as account numbers, holdings, or transaction history) through the Site. That information, where applicable, is collected and governed separately under our GLBA/Regulation S-P privacy notice provided directly to investors.

3. How We Use Information

We may use the information described above to:

4. Cookies and Analytics

The Site uses cookies and similar technologies (such as web beacons and tracking pixels), including third-party analytics services such as Google Analytics, to understand how visitors use the Site and to help us improve it. These technologies may collect information such as your IP address, browser and device type, pages viewed, and time spent on the Site.

You can control cookies through your browser settings, including blocking or deleting cookies. If you disable cookies, some features of the Site may not function properly. [If you use advertising pixels/remarketing, add detail here and, for California visitors, ensure this is reflected in your "Do Not Sell or Share" disclosure below.]

5. How We Share Information

We do not sell your personal information for money. We may share information collected through the Site with:

Some analytics and advertising cookies described in Section 4 may constitute a "sale" or "sharing" of personal information as broadly defined under California law, even though no money changes hands. See Section 6 for your related rights.

6. Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), gives you certain rights regarding personal information we collect about you through the Site. These rights include:

To submit a request, please contact us at [INSERT PRIVACY CONTACT EMAIL/FORM]. We may need to verify your identity before completing certain requests. You may also designate an authorized agent to submit a request on your behalf.

To opt out of the sale or sharing of your personal information collected through cookies, [INSERT: link to "Do Not Sell or Share My Personal Information" mechanism, cookie preference tool, or opt-out instructions]. In the preceding 12 months, we [have / have not — CONFIRM] sold or shared personal information as those terms are defined under the CCPA.

Note: Nonpublic personal information collected in connection with an actual or prospective advisory or fund investor relationship, and subject to GLBA and Regulation S-P, is generally exempt from certain CCPA provisions. This Section 6 applies to personal information collected through the Site outside that context (e.g., general visitor, prospect, and job applicant data).

7. Children's Privacy

The Site is not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child without appropriate consent, we will take steps to delete that information.

8. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information collected through the Site from unauthorized access, use, disclosure, alteration, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Data Retention

We retain personal information collected through the Site for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.

10. Third-Party Links

The Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those third-party sites, and we encourage you to review their privacy policies.

11. International Visitors

The Site is directed to visitors in the United States. If you access the Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. [If you have EU/UK visitors or process EU personal data, this section requires GDPR-specific disclosures — legal basis for processing, data subject rights, international transfer mechanism, and an EU representative/DPO contact, as applicable. Consult counsel before relying on this abbreviated section for EU visitors.]

12. Changes to This Policy

We may update this Policy from time to time. The "Effective Date" above reflects the date of the most recent revision. Material changes will be posted on this page.

13. Contact Us

If you have questions about this Policy or wish to exercise your privacy rights, please contact:

IWP Op Co, LLC, 110 Traders Cross, Floor 1, Bluffton, SC

Admin@IWPurpose.com