Privacy Policy

Scope of Policy: This Privacy Policy applies solely to information collected through the Qleario website. Use of Qleario’s technology products and advisory services is governed by the specific Master Service Agreements (MSA) and Data Processing Addendums (DPA) executed between Qleario and its institutional partners.

Last Modified: February 23, 2026 | Effective Date: February 12, 2026

Introduction: This Privacy Policy informs you of our procedures regarding the collection, use, and disclosure of information on our Site. In this Policy, Qleario, Inc. will be referred to as "Qleario," "our," "us," or "we."

As used in this Policy, the terms "using" and "processing" information include the use of cookies, the performance of statistical analysis, and the handling of information in any way—including collecting, storing, evaluating, and transferring information within Qleario or its affiliates.

Agreement and Modifications: By utilizing this Site, you acknowledge the terms of this Privacy Policy. This Policy may be modified periodically at our discretion. We will notify users of any changes by posting the updated Policy and amending the "Last Modified" date at the top of this page.

Personally Identifiable Information (PII): This Policy has been compiled to serve those concerned with how their Personally Identifiable Information (PII) is utilized online. Under U.S. privacy and information security standards, PII is information that can be used on its own or with other data to identify, contact, or locate an individual. Please read this document carefully to understand how we collect, protect, and handle your PII in accordance with our Site operations.

What personal information do we collect from the people that visit our website? When inquiring or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, or other professional details to assist with your experience and facilitate our advisory services.

When do we collect information? We collect information from you when you register on our site, fill out a formal inquiry form, subscribe to a newsletter, or otherwise enter information on our site.

How do we use your information? Qleario utilizes the information collected from you when you register, sign up for our newsletter, respond to a survey, or interact with our website to enhance our professional services. Specifically, we use this information to administer site features, respond to marketing communications, and streamline the delivery of information regarding our advisory portfolio. Additionally, we utilize aggregate data from site interactions to improve our digital infrastructure and ensure a more efficient experience for our visitors.

How do we protect visitors’ information? Qleario maintains a rigorous security framework designed to protect the integrity of all visitor data. Our digital infrastructure undergoes systematic scanning for vulnerabilities and known security gaps to ensure a secure browsing environment, supplemented by continuous malware monitoring protocols. All personal information is stored within encrypted, secured networks, with access strictly limited to a foundational group of personnel who possess specific administrative rights and are contractually bound to maintain rigorous confidentiality. Furthermore, all data transmitted via the Site is protected using Secure Socket Layer (SSL) technology. To ensure maximum operational security, we implement a comprehensive suite of safety measures during the submission or access of information and do not store sensitive transactional data on our local servers, utilizing specialized, secure gateway providers for all such interactions.

SOC 2 Type II Compliance: Qleario maintains a SOC 2 Type II attestation covering the Security, Availability, and Confidentiality Trust Services Criteria as established by the American Institute of Certified Public Accountants (AICPA). Our SOC 2 Type II report evaluates the design and operating effectiveness of our internal controls over a defined audit period. Copies of our current SOC 2 Type II report are available to customers and prospective customers upon written request and subject to the execution of a nondisclosure agreement, where applicable.

Use of Cookies: Qleario utilizes cookies—small files transferred to your device through your web browser—to enhance Site functionality and improve user experience. These cookies allow our systems to recognize your browser and retain certain non-identifying preferences for future visits. We use this data in the aggregate to monitor Site traffic and interaction patterns, enabling us to optimize our digital infrastructure and tools. Users may manage cookie preferences through their individual browser settings; however, disabling cookies may limit the functionality of certain features on our Site.

Third-Party Disclosure: Qleario does not sell, trade, or otherwise transfer your Personally Identifiable Information to outside parties. This excludes trusted third parties who assist us in operating our website, conducting our business, or servicing our clients, provided that those parties are contractually obligated to maintain the confidentiality of such information. We may also release information when appropriate to comply with legal requirements, enforce our site policies, or protect the rights, property, or safety of Qleario or others. We do not provide non-personally identifiable visitor information to outside parties for marketing, advertising, or other commercial purposes.

Third-Party Links and Resources: At our discretion, we may include links to third-party websites, industry resources, or professional services on our Site. These external platforms maintain separate and independent privacy policies. Consequently, Qleario assumes no responsibility or liability for the content, security, or activities of these linked sites. We nonetheless strive to maintain the integrity of our digital presence and welcome feedback regarding the relevance and security of any external resources provided through our Site.

Google Services: Qleario does not utilize Google AdSense or other third-party behavioral advertising platforms on our Site. We do not permit third-party vendors to serve advertisements to our users based on their interactions with our digital infrastructure. While we may utilize internal Google tools for Site optimization and performance monitoring, we do not share Personally Identifiable Information with Google for the purposes of cross-site tracking or advertising impressions.

California Online Privacy Protection Act (CalOPPA): In accordance with CalOPPA, Qleario maintains full transparency regarding our data practices. We provide a conspicuous link to this Privacy Policy on our homepage, ensuring it is easily accessible to all visitors. Users may navigate our site anonymously, and any updates to our privacy protocols will be reflected on this page with an updated "Last Modified" date. We are committed to ensuring that California consumers and all site visitors can exercise their privacy rights; individuals who wish to review, update, or request the deletion of any personal information provided to us may do so by contacting our privacy team directly via the contact information provided at the conclusion of this Policy.

How Does Our Site Handle Do Not Track Signals? In accordance with CalOPPA, Qleario acknowledges "Do Not Track" (DNT) browser signals; however, due to the lack of a universal industry standard for signal interpretation, our Site maintains its standard operational and security protocols while continuing to honor the privacy preferences outlined throughout this Policy.

Children’s Online Privacy Protection Act (COPPA): Qleario’s website and services are directed exclusively to business professionals and institutional partners. In compliance with COPPA, we do not knowingly collect, solicit, or maintain personal information from children under the age of 13. If we become aware that we have inadvertently collected information from a child under the age of 13, we will take immediate steps to delete that data from our systems.

Fair Information Practices: In the event of a significant data breach, Qleario will notify affected users via email within seven business days. We adhere to the Individual Redress Principle, acknowledging the right of individuals to pursue legally enforceable rights against data collectors and processors who fail to adhere to established law.

Our Commitment to Compliance: To ensure full adherence to the CAN-SPAM Act, Qleario maintains rigorous communication protocols. We prohibit the use of false or misleading subject lines or email addresses and ensure that any promotional materials are identified in a clear and reasonable manner. All official correspondence includes the physical address of our corporate headquarters, and we actively monitor third-party email service providers for continued compliance. We honor all opt-out and unsubscribe requests promptly, ensuring every commercial email includes an accessible unsubscribe link.

Contacting Us: If there are any questions regarding this privacy policy, you may contact us using the information below:

Policy Updates: Qleario reserves the right to modify this Privacy Policy at any time. Significant changes will be communicated by updating the "Last Modified" date and posting the revised Policy directly on our Site. We encourage visitors to review this page periodically for updates.