Privacy Policy

Overview

Capital Turbine ("we," "us," or "our") operates the website at capitalturbine.com and provides marketing technology services to independent financial advisors and wealth management firms. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services.

Information We Collect

We may collect the following types of information:

• Personal information you provide directly, such as your name, email address, phone number, firm name, and any other details submitted through contact forms or during onboarding.
• Usage data collected automatically, including IP address, browser type, operating system, referring URLs, pages viewed, and time spent on our website.
• Cookies and tracking technologies used to analyze website traffic, measure advertising, remember preferences, and improve our services. The "Cookies, Analytics, and Advertising" section below describes the specific tools we use and the choices you have.
• Client content and data provided to us in the course of delivering marketing services, including firm details, branding materials, client lists for marketing purposes, and content for compliance review.

Cookies, Analytics, and Advertising

Our website uses a small number of third-party tags and pixels:

• Google Analytics measures how visitors use our site — which pages are viewed, how long visits last, and how visitors arrive — so we can improve it.
• Google Ads conversion measurement tells us whether clicks on our ads lead to inquiries. We have disabled ad personalization signals on our Google tags, so they are used for measurement rather than for building advertising profiles.
• The Meta Pixel supports our advertising on Facebook and Instagram. It shares limited information about your visit — such as the pages you view, your device and browser information, and your IP address — with Meta. Meta uses this information to measure how our ads perform and to help us reach people who are more likely to be interested in our services. Some state privacy laws treat this as "sharing" personal information for targeted advertising.

You can opt out of this tracking in several ways:

• We honor the Global Privacy Control (GPC) signal. If your browser or a browser extension sends GPC, we do not load the Meta Pixel during your visit.
• You can block or delete cookies through your browser settings.
• You can manage how Meta uses information about you in your Facebook or Instagram ad preferences, and you can opt out of interest-based advertising from many companies at optout.aboutads.info.

How We Use Your Information

We use collected information to:

• Provide, operate, and improve our marketing platform and services
• Generate, distribute, and archive marketing content on your behalf
• Manage advertising campaigns across channels including programmatic, search, and social
• Respond to inquiries and provide customer support
• Maintain compliance-related records, including approval routing and audit-trail archiving
• Analyze usage patterns to improve our website and platform
• Send service-related communications and, with your consent, marketing communications

Artificial Intelligence

Our platform uses artificial intelligence to generate, edit, and screen marketing content. To provide these features, we may process information you provide — such as firm details, branding materials, and draft content — using third-party AI service providers under contractual confidentiality and data-protection obligations. We do not permit our AI service providers to use your information to train their general-purpose models. We do not include your clients' personal information in AI processing except as necessary to deliver the services you have requested.

Data Sharing and Disclosure

We do not sell your personal information for money. As described in "Cookies, Analytics, and Advertising" above, our use of the Meta Pixel shares limited website usage data with Meta for advertising purposes, which some state privacy laws treat as "sharing" or a "sale." Beyond that, we may share information with:

• Service providers who assist in delivering our services (e.g., hosting, analytics, advertising platforms, email delivery), bound by confidentiality obligations.
• Advertising partners for the purpose of running campaigns on your behalf, including demand-side platforms and social media networks.
• Legal and regulatory authorities when required by law, regulation, or legal process.
• Business transfers in connection with a merger, acquisition, or sale of assets, in which case your data would remain subject to this Privacy Policy.

Your Clients' Information

When you provide us contact lists or other information about your clients in the course of using our services, we process that information solely as a service provider on your behalf and at your direction: to deliver the marketing, distribution, and archiving services you request. We do not sell this information, use it for our own marketing, or use it to build profiles for any purpose other than delivering services to you. We recognize that our clients are subject to privacy and safeguarding obligations, including SEC Regulation S-P, and we maintain administrative, technical, and physical safeguards designed to support those obligations. Customers may request our data processing addendum at hello@capitalturbine.com.

Data Retention

We retain personal information for as long as necessary to provide our services and fulfill the purposes described in this policy. For clients using our compliance features, content and approval records are retained in accordance with applicable regulatory requirements, including archiving designed to support SEC and FINRA recordkeeping requirements, where enabled. You may request deletion of your personal information at any time, subject to any legal retention obligations.

Data Security

We implement commercially reasonable technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

Your Rights

Depending on your jurisdiction, you may have the right to:

• Access, correct, or delete the personal information we hold about you
• Object to or restrict certain processing of your data
• Withdraw consent where processing is based on consent
• Request portability of your data

To exercise any of these rights, contact us at hello@capitalturbine.com.

California and Other State Privacy Rights

If you are a resident of California or another state with a comprehensive privacy law, you may have the right to know, access, correct, delete, and obtain a copy of your personal information; to opt out of the sale or sharing of personal information and certain targeted advertising; and to not receive discriminatory treatment for exercising these rights. We do not sell personal information for money. We do share limited website usage data with Meta through the Meta Pixel for advertising purposes, as described in "Cookies, Analytics, and Advertising" above; some state laws treat this as "sharing" for cross-context behavioral advertising or as a "sale." You can opt out of that sharing at any time. We honor opt-out preference signals such as Global Privacy Control — if your browser sends one, we do not load the Meta Pixel — and the section above describes other ways to opt out. We do not knowingly sell or share the personal information of anyone under 16. Where we process personal information on behalf of our business customers, we act as a "service provider" or "processor" as defined under applicable law, and we use that information only to provide the contracted services. To exercise any right, contact us at hello@capitalturbine.com; we will verify your request and respond within the time required by applicable law. You may designate an authorized agent to make a request on your behalf.

Third-Party Links

Our website may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties and encourage you to review their policies independently.

Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children.

Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. Your continued use of our website or services after changes are posted constitutes acceptance of the revised policy.

Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at hello@capitalturbine.com.