I. Introduction

Aurelion Research (“Aurelion,” “we,” “us,” or “our”) is committed to protecting the privacy, confidentiality, and security of personal information collected from users of our website, including institutional clients, authorized users of our client portal, and general website visitors. This Privacy Policy describes how we collect, use, store, disclose, and safeguard personal information in connection with our website and related services.

By accessing or using our website or client login portal, you acknowledge that you have read and understood this Privacy Policy.

II. Scope of This Policy

This Privacy Policy applies to personal information collected through our website, client login portal, communications with us, and any related online services. It does not apply to third-party websites, platforms, or services that may be linked from our site.

III. Information We Collect

Information Provided by Users
When you access the client login portal or communicate with us, we may collect personal information including, but not limited to, names, email addresses, usernames, login credentials, and any information voluntarily provided through forms or correspondence. Login credentials are stored using encryption or hashing and are not accessible in plain text.

Automatically Collected Information
Certain technical and usage information is automatically collected when you access our website. This may include internet protocol (IP) addresses, browser type, device identifiers, operating system, access times, referring URLs, and interaction data. Such information is collected for security, fraud prevention, operational integrity, and performance monitoring purposes.

Cookies and Similar Technologies
We use essential cookies and similar technologies required for authentication, session management, and core website functionality. These technologies are necessary for the proper operation of the client login portal. Disabling them may limit or prevent access to certain website features.

IV. Use of Personal Information

Personal information is used for legitimate business purposes, including authentication and access control, delivery of research materials and administrative communications, maintenance of system security, prevention of unauthorized access, improvement of website functionality and user experience, compliance with legal and regulatory obligations, and protection of intellectual property and contractual rights.

Aurelion does not sell, rent, or trade personal information.

V. Legal Basis for Processing

Where required under applicable data protection laws, personal information is processed on one or more lawful bases, including performance of contractual obligations, legitimate business interests, compliance with legal obligations, or user consent where applicable.

VI. Data Storage and Security

Personal information is stored using secure systems and safeguarded through commercially reasonable administrative, technical, and organizational measures designed to protect against unauthorized access, disclosure, alteration, or destruction. Access to personal information is limited to authorized individuals with a legitimate business need.

While reasonable safeguards are implemented, no method of transmission over the internet or electronic storage is completely secure, and absolute security cannot be guaranteed.

VII. Data Retention

Personal information is retained only for as long as reasonably necessary to fulfill the purposes for which it was collected, including legal, regulatory, security, and contractual requirements. Information that is no longer required is securely deleted or anonymized.

VIII. Disclosure of Information

Personal information may be disclosed to trusted service providers that support website operations, security, communications, and data processing, subject to confidentiality and data protection obligations. Disclosure may also occur where required by law, regulation, legal process, or governmental request, or where necessary to protect rights, property, or safety.

IX. Third-Party Websites

Our website may contain links to third-party websites or resources. Aurelion does not control and is not responsible for the privacy practices, content, or security of such third-party sites. Users are encouraged to review the privacy policies of any external websites they visit.

X. International Data Transfers

Personal information may be processed or stored in jurisdictions outside your country of residence, which may have different data protection standards. By using our website, you acknowledge and consent to such processing in accordance with this Privacy Policy and applicable law.

XI. User Rights

Subject to applicable data protection laws, users may have the right to request access to, correction of, or deletion of personal information held by Aurelion, or to object to or restrict certain processing activities. Requests will be handled in accordance with legal requirements and may require verification of identity.

XII. No Fiduciary or Advisory Relationship

Nothing in this Privacy Policy creates or implies a fiduciary, advisory, or client relationship beyond the limited purposes described herein.

XIII. Changes to This Policy

Aurelion Research ("Aurelion," "we," "us," or "our") is committed to protecting the privacy, confidentiality, and security of personal information collected from users of our website, including institutional clients, authorized users of our client portal, and general website visitors. This Privacy Policy describes how we collect, use, store, disclose, and safeguard personal information in connection with our website and related services. By accessing or using our website or client login portal, you acknowledge that you have read and understood this Privacy Policy.

II. Privacy Officer

Aurelion Research has designated a Privacy Officer responsible for overseeing compliance with this Privacy Policy and applicable data protection laws, including Quebec's Act respecting the protection of personal information in the private sector (Law 25) and, where applicable, the General Data Protection Regulation (GDPR). For any questions, concerns, or requests relating to your personal information, please contact our Privacy Officer at contact@aurelionresearch.com. We will respond to verified requests within the time limits prescribed by applicable law.

III. Scope of This Policy

This Privacy Policy applies to personal information collected through our website, client login portal, communications with us, and any related online services. It does not apply to third-party websites, platforms, or services that may be linked from our site, including the Plutus platform operated by Namsoft Advisors LLC.

IV. Information We Collect

Information Provided by Users. When you access the client login portal or communicate with us, we may collect personal information including, but not limited to, names, email addresses, usernames, login credentials, company affiliation, and any information voluntarily provided through forms or correspondence. Login credentials are stored using encryption or hashing and are not accessible in plain text.

Automatically Collected Information. Certain technical and usage information is automatically collected when you access our website. This may include internet protocol (IP) addresses, browser type, device identifiers, operating system, access times, referring URLs, and interaction data. Such information is collected for security, fraud prevention, operational integrity, and performance monitoring purposes.

Cookies and Similar Technologies. We use essential cookies required for authentication, session management, and core website functionality. We also use optional analytics and translation technologies, including Google Analytics and GTranslate, which may place additional cookies on your device. Non-essential cookies are only activated following your explicit consent, provided through our cookie consent interface. You may withdraw consent or manage cookie preferences at any time through your browser settings or our consent interface. Disabling essential cookies may limit or prevent access to certain website features.

V. Use of Personal Information

Personal information is used for legitimate business purposes, including authentication and access control, delivery of research materials and administrative communications, maintenance of system security, prevention of unauthorized access, improvement of website functionality and user experience, compliance with legal and regulatory obligations, and protection of intellectual property and contractual rights. Aurelion does not sell, rent, or trade personal information.

VI. Legal Basis for Processing

Where required under applicable data protection laws, including Quebec's Law 25 and the GDPR for users in the European Economic Area, personal information is processed on one or more lawful bases, including performance of contractual obligations, legitimate business interests, compliance with legal obligations, or user consent where applicable. Where consent is relied upon as a lawful basis, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

VII. Data Storage and Security

Personal information is stored using secure systems and safeguarded through commercially reasonable administrative, technical, and organizational measures designed to protect against unauthorized access, disclosure, alteration, or destruction. Access to personal information is limited to authorized individuals with a legitimate business need. While reasonable safeguards are implemented, no method of transmission over the internet or electronic storage is completely secure, and absolute security cannot be guaranteed. In the event of a privacy incident involving your personal information, Aurelion will notify affected individuals and relevant authorities as required by applicable law.

VIII. Data Retention

Personal information is retained only for as long as reasonably necessary to fulfill the purposes for which it was collected, including legal, regulatory, security, and contractual requirements. Information that is no longer required is securely deleted or anonymized.

IX. Disclosure of Information

Personal information may be disclosed to trusted service providers that support website operations, security, communications, and data processing, subject to confidentiality and data protection obligations. Disclosure may also occur where required by law, regulation, legal process, or governmental request, or where necessary to protect the rights, property, or safety of Aurelion, its users, or the public. Aurelion does not sell or disclose personal information to third parties for their own marketing purposes.

X. Third-Party Websites

Our website may contain links to third-party websites or resources, including the Plutus platform operated by Namsoft Advisors LLC. Aurelion does not control and is not responsible for the privacy practices, content, or security of such third-party sites. Users are encouraged to review the privacy policies of any external websites they visit before providing personal information.

XI. International Data Transfers

Personal information may be processed or stored in jurisdictions outside your country of residence, which may have different data protection standards. Where such transfers occur, Aurelion implements appropriate safeguards to ensure that personal information continues to be protected in accordance with this Privacy Policy and applicable law.

XII. Your Rights

Subject to applicable data protection laws, including Quebec's Law 25 and the GDPR, you may have the right to request access to, correction of, or deletion of personal information held by Aurelion, to object to or restrict certain processing activities, to withdraw consent where processing is based on consent, and to lodge a complaint with a supervisory authority. To exercise any of these rights, please contact our Privacy Officer at contact@aurelionresearch.com. We will respond within the time limits prescribed by applicable law.

XIII. No Fiduciary or Advisory Relationship

Nothing in this Privacy Policy creates or implies a fiduciary, advisory, or client relationship between Aurelion Research and any user beyond the limited data protection purposes described herein.

XIV. Changes to This Policy

Aurelion reserves the right to update or modify this Privacy Policy at any time. Changes become effective upon posting to this page. Where changes are material, we will make reasonable efforts to provide notice. Continued use of the website following the posting of any changes constitutes your acceptance of the revised Privacy Policy.