Legal and Regulatory

Firm Registration

MultiPolar Capital LLC is a Registered Investment Advisor in the State of California. Registration of an investment advisor does not imply any specific level of skill or training.

Risk Disclosure

All investing involves risk, including the potential loss of principal. Past performance is not a guarantee of future results.

Third-Party Links Disclaimer

For your convenience, MultiPolar Capital LLC may provide links to websites operated by third parties. MultiPolar Capital LLC is not responsible for the content, accuracy, or privacy practices of these external sites. The inclusion of any link does not imply an endorsement, sponsorship, or recommendation by MultiPolar Capital LLC of the site, its operator, or its contents.

Custody & Brokerage

Account custody and trade execution are provided by third-party institutions such as Interactive Brokers LLC. Such entities are separate and independent from MultiPolar Capital LLC.

Cross-Border / Expat Disclosure

MultiPolar Capital LLC specializes in serving U.S. citizens residing domestically and abroad. Our services are only offered in jurisdictions where the firm is appropriately registered or exempt from registration. Clients residing outside the United States are responsible for all local tax reporting and compliance requirements in their country of residence. MultiPolar Capital LLC does not provide tax or legal advice.

Our Commitment to Your Privacy

MultiPolar Capital LLC values the trust you place in us. As a fiduciary, we are committed to maintaining the confidentiality, integrity, and security of the personal and financial information entrusted to us by our clients, both domestic and international.

Information We Collect

In the course of providing investment advisory services, we collect and maintain “nonpublic personal information” (NPI) about you. This information includes, but is not limited to:

• Information from Applications and Forms: Name, address, Social Security Number or Tax ID, date of birth, assets, and income.
• Information about Your Transactions: Account balances, transaction history, and investment experience with us or our service providers.
• Information from Website Usage: Information collected through “cookies” or similar technologies to enhance site security and functionality.

How We Share Information

MultiPolar Capital LLC does not sell your personal information to anyone. We only disclose nonpublic personal information about you to nonaffiliated third parties in the following limited circumstances:

• To Service Your Account: We share information with financial institutions to execute transactions and manage your assets, specifically Interactive Brokers LLC.
• As Required by Law: We share information to comply with subpoenas, court orders, or regulatory inquiries from the California Department of Financial Protection and Innovation (DFPI) or other government agencies.
• Professional Services: We may share information with auditors, attorneys, or consultants who are legally or contractually bound to maintain the confidentiality of your data.

Confidentiality and Security

We maintain strict physical, electronic, and procedural safeguards to protect your nonpublic personal information.

MultiPolar utilizes a “Hard Split” architecture to ensure client data is isolated from personal activities and system-wide indexing. We restrict access to your personal data to those employees or service providers who “need to know” that information to provide products or services to you.

Your California Privacy Rights (CCPA / CPRA)

As a California-registered entity, we comply with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). California residents have the following rights:

• Right to Know: You may request disclosure of what personal information we collect, use, and disclose.
• Right to Delete: You may request the deletion of personal information we have collected, subject to certain legal and regulatory retention requirements.
• Right to Opt-Out: While we do not sell your data, you have the right to opt-out of the sharing of personal information for cross-contextual behavioral advertising.

Special Notice for Expatriate and International Clients

While MultiPolar Capital LLC is a California-registered entity, we recognize the unique privacy requirements of our clients living abroad. We strive to handle your data in a manner consistent with international privacy standards, though your data will be stored and processed primarily within the United States.

Changes to This Policy

We will provide you with an updated version of this Privacy Policy annually. If we make a material change to our privacy practices that would result in sharing your information with a new category of third party, we will provide you with a revised notice and a reasonable opportunity to “opt-out” of such sharing.

Contact Information

If you have any questions or concerns regarding this policy, please contact: