Privacy Policy

I. Important Information

StocktiX values the protection of clients' personal, financial, account and identity information.

This notice is intended to help clients understand how StocktiX collects, uses, stores, shares and protects client information during the provision of investment advisory services, account-opening assistance, client support, compliance reviews and related services.

United States Regulation S-P establishes requirements for client privacy policy notification, handling of non-public personal information and protection of information security at relevant financial institutions. This regulation applies to SEC-registered investment advisers, brokers, dealers and investment companies, among other regulated entities.

II. Information That May Be Collected

StocktiX may collect the following client information during the provision of its services:

1. Identity Information

Includes, among others:

  • Name
  • Date of birth
  • Nationality
  • Identity document information
  • Passport information
  • Tax residency status
  • Contact information

2. Financial Information

Includes, among others:

  • Income level
  • Investment experience
  • Risk tolerance
  • Investment objectives
  • Source of funds
  • Documentation relating to account fund services

3. Service Information

Includes, among others:

  • Account opening progress
  • Client service records
  • Investment preferences
  • Client classification
  • Service level
  • Communication records
  • Investment advisory service records
  • Account feature requests

4. Technical Information

Includes, among others:

  • IP address
  • Login time
  • Device type
  • Browser type
  • Operating system
  • Page visit history
  • Cookies or similar technologies
  • Security verification records

III. Purpose of Information Use

StocktiX may use client information for the following purposes:

  • Verify the client's identity
  • Assist with the opening of securities accounts
  • Complete KYC (Know Your Customer) review
  • Complete anti-money laundering (AML) review
  • Conduct sanctions screening
  • Assess the client's risk tolerance
  • Provide investment advisory services
  • Offer market research and asset allocation recommendations
  • Provide client service and after-sales support
  • Handle client inquiries, complaints and requests
  • Help the client understand third-party account features
  • Comply with regulatory, audit, record-keeping and compliance obligations
  • Prevent fraud, unauthorized access, cyberattacks and other security risks
  • Improve products, services, systems and the client experience
  • Send important notices, risk alerts, account information and service updates

IV. Recipients of Information Sharing

StocktiX does not sell clients' personal information.

To the extent necessary for the provision of services and compliance with regulatory obligations, StocktiX may share client information with the following parties:

  • Third-party securities brokers
  • External clearing and settlement entities
  • External custodians
  • Identity verification service providers
  • Anti-money laundering and sanctions screening service providers
  • Technology service providers
  • Data storage providers
  • Banks or fund transfer institutions
  • Audit firms
  • Regulatory authorities
  • Law enforcement authorities
  • Other third parties authorized by the client

When the client opens a securities account, uses custody and settlement services, account fund services or third-party systems, the client should also review the privacy policies and data processing notices of those external entities.

V. Sharing with Non-Affiliated Third Parties and Client Choice Rights

To the extent permitted by applicable laws and regulations, if StocktiX needs to share a client's non-public personal information with non-affiliated third parties and such sharing does not fall within legal exceptions, StocktiX will provide the client with the corresponding notice and options in accordance with applicable regulations.

The client may, in accordance with applicable law and the procedures established by StocktiX, make the following requests:

  • Access their personal information
  • Correct inaccurate information
  • Update identity or contact details
  • Limit receipt of certain marketing messages
  • Exercise the right to opt out as provided by law
  • Inquire about the scope of information sharing
  • Withdraw part of the authorizations granted, although such withdrawal may affect the provision of certain services

VI. Information Security Protection

StocktiX will implement reasonable administrative, technical and physical measures to protect client information.

Such measures may include, among others:

  • Access control
  • Personnel confidentiality obligations
  • Data encryption
  • Identity authentication
  • Cybersecurity monitoring
  • System activity logging
  • Data backups
  • Security training
  • Third-party service provider management
  • Information retention and deletion management
  • Monitoring of suspicious activities
  • Security incident response mechanisms

VII. Data Security Incident Notification

Should a data security incident occur that may affect the security of the client's sensitive information, StocktiX will carry out the corresponding assessment, management and notification in accordance with applicable laws, regulatory requirements and its internal incident response procedures.

The notification may include:

  • General description of the incident
  • Type of information that may have been affected
  • Measures StocktiX has taken or will take to mitigate the incident
  • Protective measures the client may adopt
  • Contact channels available to the client
  • Any other information required by applicable regulations

VIII. Information Retention Period

StocktiX will retain client information in accordance with operational needs, the duration of the client relationship, applicable laws and regulations, regulatory requirements, audit needs, dispute resolution and record-keeping obligations.

When information is no longer necessary for the purposes for which it was collected, StocktiX, in accordance with applicable legislation and its internal data management policies, will take reasonable measures to delete, anonymize or securely destroy such information.

IX. Cross-Border Data Transfer

Because StocktiX offers investment advisory services and account-opening assistance in international markets, client information may be transferred, stored or processed across different jurisdictions, including Mexico, the United States or other applicable countries.

The client should understand the following:

  • Opening international accounts may require submitting client information to third-party brokers, clearing entities or custodian institutions in the United States.
  • U.S. regulatory frameworks, as well as third-party account services, custody, clearing and compliance processes, may involve the processing of client information.
  • Data protection laws may vary between different jurisdictions.
  • StocktiX will take reasonable measures, to the extent possible, to protect the security of client information.

X. Cookies and Electronic Communications

StocktiX's website, application or client systems may use cookies, log files, device identification technologies or other similar technologies for the following purposes:

  • Verify the client's identity
  • Maintain the logged-in session
  • Improve system security
  • Analyze website usage
  • Improve the client experience
  • Prevent fraud
  • Record the client's read confirmation and electronic actions

The client may manage cookies through browser or device settings; however, disabling certain functions may affect the service experience.

XI. Marketing Information

StocktiX may, with the client's consent or as permitted by applicable legislation, send the following information:

  • Market research
  • Investment education content
  • Service updates
  • Product information
  • Risk alerts
  • Client activity notifications
  • Account-related reminders

The client may, through the mechanisms provided by StocktiX, choose to unsubscribe from certain marketing messages.

However, important account-related notifications, compliance notices, risk alerts, privacy policy updates and any communications required by law may continue to be sent.

XII. Privacy of Minors

StocktiX's services are not directed at minors.

The client must not open a securities account or access investment services as a minor unless applicable legislation permits it and it is done through a legal guardian or through an account structure in accordance with current regulations.

XIII. Third-Party Privacy Policy

When the client uses services of broker-dealers, clearing entities, custodian institutions, banks, payment service providers, identity verification providers or other third-party services, those entities may collect, use, process and store client information in accordance with their own privacy policies.

StocktiX does not control the privacy policies or data processing practices of such third-party institutions.

The client should review the privacy policies, client notices and data processing statements provided by the respective third-party entities.

XIV. Privacy Policy Updates

StocktiX may update this Privacy Policy Statement periodically in accordance with changes in laws and regulations, supervisory requirements, business changes, technological advances or service adjustments.

In the event of material changes to the privacy policy, StocktiX may notify clients through the website, application, email, client portal or other reasonable means. The client's continued use of StocktiX's services shall be deemed acceptance of and understanding of the updated privacy policy content.

XV. Reading Notice for the Client

Before submitting documentation or continuing to use the services, the client should understand the following:

  • StocktiX may collect and use client information for account opening, investment advisory, client service and regulatory compliance purposes.
  • StocktiX may share client information, to the extent necessary, with broker-dealers, clearing entities, custodian institutions, technology service providers, compliance service providers and regulatory authorities.
  • If the client requests or uses financing services through third-party accounts, the relevant information may be reviewed and processed by those institutions in accordance with their own rules.
  • Cross-border investment services may involve the international transfer of client information.
  • StocktiX will take reasonable measures to protect the security of client information; however, no electronic system can guarantee absolute security.
  • The client must ensure that the information provided is truthful, accurate and complete, and must update it promptly in the event of changes.