Last Updated: 8/12/2026
Introduction
This Privacy Policy describes how Gratūs Capital, LLC, doing business as Gratūs Funds (“Gratūs Funds,” “we,” “us” or “our”), processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy, including as applicable our website, social media pages, marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”).Gratūs Funds may provide additional or supplemental privacy notices to individuals for specific products or services that we offer at the time we collect personal information. California residents: If you are a California resident, please see the Notice to California Residents section below in addition to this Privacy Policy for information about your personal information and privacy rights.
INFORMATION WE COLLECT
Personal information you may provide to usthrough the Service or otherwise includes:
Contact data, such as your first and last name, email address, mailing address, professional title or occupation, company or firm name, and phone number.
Demographic data, such as your city, state, country of residence, postal code, and age.• Profile and account data, such as the username and password you set to establish an account, date of birth, and any other information you add to your profile.
Investment data, such as your stated income level, net worth, source of funds, portfolio size, investment experience, risk tolerance, return expectations, accreditation or qualification status, and areas of investment interest.
Financial data, such as your bank account and routing numbers, wire instructions, custodial or brokerage account details, and payment information.
Transactional data, such as information needed to process and record your subscriptions, contributions, distributions and other transactions, including confirmations and transaction history.
Identity verification data, such as your taxpayer identification number and government-issued identification, collected for investor verification, tax reporting and anti-money-laundering purposes.
Communications data, based on our exchanges with you, including when you contact us through the Service, by email, by phone or otherwise.
Marketing data, such as your preferences for receiving our communications and details about your engagement with them.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
THIRD-PARTY SOURCES
We may combine personal information we receivefrom you with personal information we obtain from other sources, such as:
- Financial intermediaries, such as the financial advisors who refer you, our managing broker-dealer, fund administrator and transfer agent, escrow bank, custodians, and investment platforms.
- Public sources, such as government agencies, public records, and other publicly available sources.
- Private sources, such as data providers, identity-verification and anti-money-laundering providers, and data licensors.
- Affiliates and partners, such as our affiliates and marketing or event partners.
- Third-party services, such as services you use to log into or otherwise link to your account, which may share your username and other information based on your settings on that service.
- Financial intermediaries, such as the financial advisors who refer you, our managing broker-dealer, fund administrator and transfer agent, escrow bank, custodians, and investment platforms.
- Public sources, such as government agencies, public records, and other publicly available sources.
- Private sources, such as data providers, identity-verification and anti-money-laundering providers, and data licensors.
- Affiliates and partners, such as our affiliates and marketing or event partners.
- Third-party services, such as services you use to log into or otherwise link to your account, which may share your username and other information based on your settings on that service.
automatic data collection
We, our service providers and our business partners may automatically log information about you, your device, and your interaction over time with the Service and our communications, such as:
- Device data, such as your device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type, IP address, unique identifiers, language settings, and general location information such as city, state or geographic area.
- Online activity data, such as the pages or screens you viewed, how long you spent on a page, the website you visited before browsing to the Service, navigation paths, access times, and whether you have opened our emails or clicked links within them.
- Communication interaction data, such as your interactions with our email and other communications, which we may measure using pixel tags (also known as clear GIFs) that may be embedded in our emails.
COOKIES AND OTHER TECHNOLOGIES
Your data is accessible only by aSome of the automatic collection described above is facilitated by the following technologies:
- Cookies, which are small text files that websites store on user devices to record browsing activity and remember submissions, preferences and login status. We use both session and persistent cookies, and both first-party cookies and third-party cookies placed by our business partners and service providers.
- Local storage technologies, such as HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device.
- Web beacons, also known as pixel tags or clear GIFs, which are used to show that a webpage or email was accessed or opened, or that content was viewed or clicked.
We use analytics tools such as Google Analytics to understand how our Website is used and to measure the performance of our content.
DATA ABOUT OTHERS
We may offer features, such as referral or invitation features, that let you provide contact details for other people. Please do not refer someone to us or share their contact details unless you have their permission to do so.
HOW WE USE YOUR PERSONAL INFORMATION
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations: We may use your personal information to provide, operate and improve the Service and our business; establish and maintain your account and profile on the Service; process and service your subscriptions, contributions, distributions and other transactions; verify your identity and eligibility, including accreditation and qualification status, and meet our know-your-customer and anti-money-laundering obligations; enable security features, such as sending you security codes and remembering devices from which you have previously logged in; communicate with you about the Service, including Service-related announcements, updates, security alerts, and support and administrative messages; communicate with you about events in which you participate; and provide support, and respond to your requests, questions and feedback.
Research and development: We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.
Marketing and advertising: We may send you direct marketing communications and may personalize these messages based on your interests. You may opt out of our marketing communications as described in the Your choices section below. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction with the Service and other online services over time, and use that information to serve ads they think will interest you. We may also share information about our users with these companies to facilitate interest-based advertising. We may use your personal information to analyze your use of the Service, understand which pages are most and least visited and how visitors move around the Service, measure interactions with our emails, and improve the Service and our business.
Service improvement and analytics: We may use your personal information to analyze your use of the Service, understand which pages are most and least visited and how visitors move around the Service, measure interactions with our emails, and improve the Service and our business.
Compliance and protection: We may use your personal information to: comply with applicable laws, including identity-verification, anti-money-laundering and sanctions laws, lawful requests, and legal process, such as responding to subpoenas, investigations or requests from government authorities; protect our, your or others’ rights, privacy, safety or property, including by making and defending legal claims; audit our internal processes for compliance with legal, contractual and internal-policy requirements; enforce the terms that govern the Service; and• prevent, identify, investigate and deter fraudulent, harmful, unauthorized or illegal activity, including cyberattacks, identity theft and money laundering.
To create aggregated, de-identified or anonymized data: We may create aggregated, de-identified or anonymized data from personal information and use and share it for our lawful business purposes, including to analyze and improve the Service and promote our business. We do not attempt to reidentify this data.
Further uses: In some cases we may use your personal information for further purposes. Where those purposes are not compatible with the purpose for which the information was collected, we will ask for your consent.
Retention: We generally retain personal information to fulfill the purposes for which we collected it, including to satisfy legal, accounting, tax and reporting requirements, to establish or defend legal claims, and for fraud prevention. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the information, the potential risk of harm, the purposes for which we process it, and applicable legal requirements. Financial and securities records may be retained for several years after your relationship with us ends. When we no longer require the information, we delete, anonymize or isolate it from further processing.
HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection:
- Affiliates. Our corporate parent, subsidiaries and affiliates.
- Service providers. Third parties that provide services on our behalf or help us operate the Service or our business, such as hosting, information technology, customer support, email delivery, marketing, and website analytics providers.
- Financial and transaction partners. Parties that help us administer offerings and process transactions, such as our managing broker-dealer, fund administrator and transfer agent, escrow bank, custodians, payment processors, and investment platforms. These parties may use your personal information in accordance with their respective privacy policies.
- Identity verification providers. Third parties that help us verify your identity and meet anti-money-laundering and know-your-customer requirements.
- Authorities and others. Law enforcement, government authorities and private parties, as we believe in good faith is necessary or appropriate for the compliance and protection purposes described above.
YOUR CHOICES
Opt out of communications. You may opt out of marketing-related emails by following the unsubscribe instructions at the bottom of the email, or by contacting us. If you choose to opt out, you may continue to receive service-related and other non-marketing messages, such as transaction confirmations and required notices.
Cookies. Most browsers let you remove or reject cookies through their settings. If you disable cookies, the Service may not work properly. For more information, including how to see and manage the cookies on your browser, visit
www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.
Advertising choices. You may be able to limit the use of your information for interest-based advertising by changing your browser settings to block third-party cookies, using privacy browsers or ad-blocking plug-ins, using platform opt-out features offered by companies such as Google and Meta, and using industry opt-out tools such as those offered by the Network Advertising Initiative and the Digital Advertising Alliance. You will need to apply these settings on each device and browser you use. We cannot offer assurances as to whether the companies we work with participate in these programs.
Do Not Track. Some browsers can be configured to send “Do Not Track” signals. Because there is no common industry standard for these signals, we currently do not respond to them. We honor recognized opt-out preference signals, such as the Global Privacy Control, where required by law.
Declining to provide information. We need to collect certain personal information to provide our products and services. If you do not provide information we identify as required, we may not be able to provide those services.
OTHER SITES AND SERVICES
The Service may contain links to websites and other online services operated by third parties, and our content may be integrated into services not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control and are not responsible for third-party services, and we encourage you to read their privacy policies.
SECURITY
We employ technical, organizational and physical safeguards designed to protect the personal information we collect, and we maintain an information-security and incident-response program. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
CHILDREN
Our services are not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information from a child without the consent required by law, we will comply with applicable legal requirements to delete the information.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by updating the date of this Privacy Policy and posting it on the Service or by other appropriate means. Any modifications are effective when we post the modified version. Your use of the Service after the effective date indicates that the modified Privacy Policy applies to your interactions with the Service and our business.
NOTICE TO CALIFORNIA RESIDENTS
This section provides additional information for California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). The rights below apply to personal information within the scope of the CCPA, subject to certain exceptions.
Subject to certain exceptions, California residents have the following rights: The right to know and access the categories and specific pieces of personal information we have collected, the sources, the business purposes for collecting it, and the categories of third parties with whom we share it; The right to delete personal information we collected from you, subject to legal exceptions such as records we must retain; The right to correct inaccurate personal information we maintain about you; The right to opt out of any “sale” or “sharing” of your personal information for cross-context behavioral advertising, as those terms are defined by the CCPA; The right to limit the use of certain sensitive personal information to permitted purposes; The right to non-discrimination for exercising any of your privacy rights.
To exercise these rights, email us at the address below. We will respond within the timeframes required by law, generally within 45 days, and we may need to verify your identity before fulfilling your request. You may use an authorized agent to submit a request on your behalf.
Contact Us
Email:
hello@gratusfunds.comMail: 718 N Washington Avenue, Floor 4, Minneapolis, MN 55401, Attention: Privacy
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