Privacy Policy
Last updated March 2026
This Privacy Policy describes how Fairlead Strategies LLC (“FS”), together with its affiliated entities Fairlead Asset Management LLC (“FAM”) and Fairlead Holdings LLC (“Holdings”) (collectively, the “Firm”), collects, uses, and protects nonpublic personal information.
FAM is an SEC-registered investment adviser that serves as sub-adviser to an investment fund (the “Fund”) and does not maintain direct relationships with underlying investors. FS is also an SEC registered investment adviser and provides investment advisory services, including research, market commentary, and subscription-based advisory and consulting services, and is the primary entity that collects personal information from clients, subscribers, and users. Holdings provides administrative and operational support and does not independently collect personal information.
Categories Of Information We May Collect
In the ordinary course of business, FS may collect the following types of nonpublic personal information:
Information provided directly by you when registering for services, subscribing to products, or communicating with the Firm (e.g., name, email address, billing information, and payment details);
Information about your interactions with our services, including usage data, access times, and content viewed; and
Information collected through our website or related digital platforms.
How We Use Your Information That We Collect
The Firm uses collected information to:
Provide, maintain, and improve products and services;
Process transactions and fulfill subscription or service requests;
Communicate with users regarding services, updates, or support;
Enforce agreements and protect the Firm’s legal rights; and
Comply with applicable legal and regulatory obligations.
The Firm may also use contact information to provide updates or information about services, subject to applicable opt-out rights.
Disclosure of Information
The Firm does not sell nonpublic personal information.
The Firm may share nonpublic personal information as permitted by applicable law, including:
With affiliated entities (FAM, FS, and Holdings) for legitimate business purposes;
With service providers (e.g., payment processors, technology providers, legal and compliance advisors) that assist in delivering services, subject to confidentiality obligations;
To comply with legal or regulatory requirements, including subpoenas, court orders, or regulatory inquiries; and
To protect the rights, property, or safety of the Firm or others.
Confidentiality and Security
The Firm maintains administrative, technical, and physical safeguards reasonably designed to protect nonpublic personal information against unauthorized access, use, or disclosure. Access to such information is limited to personnel and service providers who require it for legitimate business purposes. Information is retained only for as long as necessary to fulfill business or legal requirements and is disposed of in a secure manner when no longer needed.
Accessing and Updating Information
You may request access to, correction of, or deletion of your personal information by contacting the Firm at: info@fairleadstrategies.com. The Firm will make reasonable efforts to accommodate such requests, subject to applicable legal and operational requirements.
Third-Party Websites
The Firm’s website may contain links to third-party websites. The Firm is not responsible for the privacy practices or content of such websites. Users are encouraged to review the privacy policies of those third parties.
California Privacy Rights
California residents may have additional rights under applicable law, including the right to request information regarding certain disclosures of personal information. To submit a request, please contact: info@fairleadstrategies.com with “California Privacy Rights” in the subject line.
Changes to This Privacy Policy
The Firm may update this Privacy Policy from time to time. Any changes will be posted on the Firm’s website and will become effective upon posting. Where required, the Firm will provide notice of material changes.
Questions
For questions regarding this Privacy Policy, please contact: info@fairleadstrategies.com