
Privacy Policy/Disclaimers
Privacy Policy
Owner and Data Controller
Divergent Capital Asset Management LLC
3785 NW 82nd Ave, Unit 304
Doral, FL 33166
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Owner contact email: chris@divergentcapitalam.com
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Types of Data We Collect
In the course of your interaction with our website, www.divergentcapitalam.com, we may collect various types of Personal Data, including but not limited to: first name, last name, phone number, email address, Cookies, and Usage Data. Detailed information for each data type is available in dedicated sections of this privacy policy.
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How We Process Your Data
To safeguard your data, we employ security measures to prevent unauthorized access, disclosure, or alteration. Our processing methods adhere to organizational procedures closely tied to the purposes indicated. The processing may occur at our operating offices and other locations relevant to the processing parties.
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How Long We Retain Your Data
Your Personal Data is processed and stored for the duration necessary to fulfill the purpose for which it was collected. We may retain it for longer due to legal obligations or for resolving disputes and enforcing agreements.
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Purposes of Processing
We collect User data to provide our services, meet legal obligations, respond to enforcement requests, protect our interests, and detect malicious or fraudulent activity. This includes contacting users, analytics, marketing, and enhancing our services.
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Detailed Information on Data Processing
Analytics
Google Analytics (Google Inc.)
Google Analytics assists in web analysis and utilizes Cookies and Usage Data.
Place of processing: United States
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Marketing
We may share your information with third-party service providers to support our business operations and improve the products and services we offer.
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Ensuring Your Data Security
We limit access to your personal information to those employees, affiliates, and service providers who need it for our business purposes. We protect your personal information using safeguards that align with applicable laws, regulations, and industry-accepted practices. This includes measures that are administrative, physical, and technical in nature. We use reasonable measures to secure our websites and protect the personal information that may be shared over these sites.
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We select our third-party service providers carefully and seek contractual assurances that each third-party service provider reasonably safeguards your personal information in a manner consistent with our policies and practices.
If we discover a breach of the security of your personal information in our possession, we may notify you of that development. If such a notification is appropriate, we will endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.
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Cookies, Tracking Pixels, and Related Technologies
If you visit any of our websites, we may use first- and third-party "cookies" (small text files sent from our websites to your hard drive), tracking pixels, and/or related technologies to help us understand how our visitors interact with our websites. Cookies, tracking pixels, and related technologies help us recognize repeat visitors and improve the functionality and effectiveness of our websites. In limited cases, we may use cookies, tracking pixels, and related technologies to gather information about you. You may use the settings in your Web browser to opt-out of (i.e., block) such cookies, tracking pixels, and related technologies
Use of Services By Minors
Divergent Capital Asset Management LLC does not knowingly collect, use, or share personal information from individuals under eighteen (18) years old. We ask that any person under age 18 refrain from using our products and services. If we learn that we have collected the personal information of a minor, we will take steps to delete the personal information as soon as possible.
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Data Collection and Use
We respect your privacy and are committed to protecting the personal information you share with us. In compliance with relevant state and federal privacy laws, including the Gramm-Leach-Bliley Act (GLBA), Florida Information Protection Act (FIPA), and California Consumer Privacy Act (CCPA), this notice describes how we collect, use, and protect your personal information when you visit our website or use our services.
By using our site, you acknowledge that we collect and process certain data from end users, which may include personal information. This data may be associated with visitation information collected by Google Analytics, such as:
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IP addresses
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Browser type
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Device information
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Pages viewed
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Time spent on site
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Other behavioral data
Google Analytics collects this data to analyze and understand user behavior, improve site functionality, and provide better user experiences. This data may be combined with any personal information you provide us directly, such as contact information or inquiries submitted via forms on our site.
Consent for Data Collection and Processing
By using our website, you consent to the collection, processing, and association of your data with Google Analytics tracking, as permitted by applicable privacy laws. You also have the right to opt out of Google Analytics tracking via the use of browser settings or Google’s opt-out tools. For more information on how Google Analytics collects and processes data, please visit Google’s Privacy Policy.
Your Rights
Depending on your jurisdiction, you may have the following rights concerning your personal data:
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Right to access: You may request a copy of the personal information we hold about you.
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Right to correction: You may request corrections to any inaccurate or incomplete personal information.
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Right to deletion: You may request the deletion of your personal information, subject to certain legal exceptions.
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Right to opt-out: You may opt-out of Google Analytics tracking by adjusting your browser settings or using the Google Analytics opt-out browser add-on.
Data Security
We maintain physical, electronic, and procedural safeguards to protect your personal information in compliance with federal regulations and industry best practices.
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Contact Information
Divergent Capital Asset Management LLC
Attention: Privacy Official
3785 NW 82nd Ave, Unit 304, Doral, FL 33166
800.834.6549
chris@divergentcapitalam.com.
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Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to this Website, if not stated otherwise within this document.
Divergent Capital Asset Management LLC Disclosures
Divergent Capital Asset Management LLC (“DCAM”) is a registered investment advisor offering advisory services in the States of Florida, Georgia, Texas, Louisiana, Colorado, California and in other jurisdictions where exempted. Registration does not imply a certain level of skill or training.
This website is for informational purposes only and none of the information provided is intended as investment, tax, accounting or legal advice, as an offer or solicitation of an offer to buy or sell, or as an endorsement of any company, security, fund, or other securities or non-securities offering. Nothing herein should be interpreted to state or imply that past results are an indication of future returns. All investments involve risk and, unless otherwise stated, are not guaranteed.