Privacy Policy
Last updated October 2026
Fairlead Strategies LLC ("Fairlead Strategies," "FS," or "Fairlead"), together with its affiliated entities Fairlead Asset Management LLC ("FAM") and Fairlead Holdings LLC ("Holdings"), is committed to protecting the privacy and confidentiality of personal information collected in connection with its business activities.
This Privacy Policy describes the categories of information we collect, how that information is used and disclosed, the safeguards maintained to protect it, and the rights individuals may have concerning their information.
1. Scope and Corporate Information
Fairlead Strategies LLC is an investment adviser registered with the U.S. Securities and Exchange Commission ("SEC") in reliance on its status as a related adviser of Fairlead Asset Management LLC. Fairlead Asset Management LLC is a separately registered investment adviser that provides investment advisory and sub-advisory services to investment funds. Both entities are subsidiaries of Fairlead Holdings LLC, which provides administrative, operational, and other support services.
This Privacy Policy applies to personal information collected or processed in connection with Fairlead's websites, research subscriptions, investment advisory and research consulting services, client portals, analytical tools, software applications, business communications, and related operations. These Services include Fairlead Technical Intelligence ("FTI"), Fairlead's automated technical analysis platform.
This Policy also describes information-sharing practices among affiliated entities where information is processed for legitimate business, administrative, operational, security, or regulatory purposes.
FS and FAM are subject to applicable federal securities laws and regulations, including relevant requirements of Regulation S-P concerning the privacy and safeguarding of customer information. Where a separate regulatory privacy notice is required, that notice supplements this Privacy Policy. Nothing in this Policy limits any privacy protection or other right provided by applicable law.
2. Categories of Personal Information We Collect
Depending on the nature of an individual's relationship with Fairlead, we may collect the following categories of information.
Contact and Identification Information. Names, business affiliations, job titles, email addresses, telephone numbers, mailing addresses, and other information provided when registering for Services, subscribing to research, requesting information, or communicating with Fairlead.
Account and Subscription Information. Account identifiers, usernames, subscription plans, authorized users, account status, billing arrangements, subscription history, renewal dates, service entitlements, usage allowances, and related administrative records.
Billing and Transaction Information. Billing addresses, invoices, payment status, transaction history, payment confirmations, and information necessary to administer subscriptions and process payments. Payments may be processed by third-party payment service providers. Payment information collected directly by those providers is subject to their applicable privacy and security practices.
Communications and Client Relationship Information. Correspondence, inquiries, service requests, research-related communications, subscription preferences, and records of interactions with Fairlead personnel. This may include information maintained in customer relationship management systems to administer subscriptions, respond to inquiries, provide client service, and maintain business records.
Website and Technical Information. Internet Protocol addresses, browser types, device information, operating systems, access times, pages visited, referring websites, session information, authentication activity, and other technical information associated with use of our websites and digital Services.
Research Platform and Analytical Usage Information. When individuals use Fairlead's analytical platforms, including FTI, we may collect information associated with their use of those Services. This may include securities or ticker symbols searched or analyzed, selected analytical timeframes, saved watchlists, alert preferences and activity, feature usage, analysis counts, timestamps, account entitlements, login activity, and related activity records. We may also maintain records of user acceptance of applicable Terms of Use, product-specific agreements, disclosures, and acknowledgments, including the version accepted and associated date, time, and account information.
Such information may be used to provide requested analytical services, administer subscription allowances, maintain platform functionality, improve analytical tools, troubleshoot technical issues, document user acknowledgments, comply with regulatory obligations, and protect against unauthorized use.
Investment Advisory and Consulting Information. In connection with investment advisory or research consulting services, we may receive information concerning client investment interests, watchlists, portfolio holdings, investment objectives, research requests, or other information voluntarily provided by subscribers. The nature and extent of this information depend on the applicable subscription or advisory relationship. FTI does not independently evaluate a user's financial circumstances or investment objectives when generating automated technical analysis.
Other Information. We may collect additional information voluntarily provided through correspondence, surveys, forms, support requests, or other interactions with Fairlead.
3. Sources of Personal Information
We may collect personal information directly from individuals when they register, subscribe, communicate with us, or use our Services; from authorized representatives of institutional subscribers; automatically through websites, client portals, applications, cookies, and similar technologies; from payment processors, subscription administration systems, and other service providers; from business contacts, referrals, publicly available professional information, and other lawful sources; and from affiliated entities where appropriate for legitimate business or regulatory purposes.
4. How We Use Personal Information
Fairlead may use personal information to:
Establish, maintain, and administer subscriptions, advisory relationships, and client accounts.
Provide research publications, consulting services, client portals, analytical tools, and other Services.
Process payments, issue invoices, manage renewals, and maintain billing records.
Authenticate users and enforce subscription permissions, authorized-user limits, and usage allowances.
Deliver requested technical analyses, maintain watchlists, administer alerts, and support other analytical functionality.
Respond to inquiries, provide technical support, and communicate with subscribers.
Maintain customer relationship records and manage business relationships.
Operate, maintain, troubleshoot, secure, and improve our websites and analytical platforms.
Evaluate service usage, functionality, reliability, and performance.
Develop and refine analytical functionality using appropriately controlled data.
Provide requested research consulting and investment advisory services.
Detect, investigate, and prevent unauthorized access, fraud, misuse, and security incidents.
Document acceptance of applicable agreements, disclosures, and acknowledgments.
Maintain records required for accounting, legal, regulatory, and compliance purposes.
Protect Fairlead's contractual rights, intellectual property, and legitimate business interests.
Comply with applicable laws, regulations, legal processes, and regulatory obligations.
We may also use business contact information to communicate about Fairlead research, products, events, publications, and services, subject to applicable law and available opt-out rights.
5. Research Activity and Analytical Platform Data
Fairlead's analytical Services, including FTI, may process information relating to securities searched, charts viewed, analytical tools accessed, watchlists maintained, alerts configured, analysis requests submitted, and other platform activity. This information may be associated with an individual subscriber account or institutional subscription.
We may use such information to deliver requested analytical results; maintain saved settings, watchlists, and alert preferences; administer subscription entitlements and usage limits; identify and resolve technical issues; evaluate and improve platform performance; detect unusual activity or unauthorized use; and develop and refine analytical functionality using appropriately controlled data.
Authorized Fairlead personnel and service providers may access analytical activity, watchlists, alerts, account usage, and related records where reasonably necessary for platform administration, customer support, troubleshooting, security, compliance, regulatory recordkeeping, and other legitimate business purposes. Such access is subject to applicable confidentiality, access-control, and legal requirements.
Securities searches, watchlists, and other platform activity should not be assumed to be anonymous when associated with an identifiable account. Fairlead does not represent that individual analytical requests or watchlists are inaccessible to personnel responsible for operating or supervising the Services.
Fairlead does not sell subscriber-specific analytical activity or watchlist information for monetary consideration. Information collected through FTI is not, by itself, treated as an individualized investment advisory instruction or a request for Fairlead to monitor or manage a subscriber's investments.
6. Disclosure and Sharing of Personal Information
Fairlead does not sell nonpublic personal information to unaffiliated third parties for their independent marketing purposes. We may disclose personal information in the following circumstances, subject to applicable law.
Affiliated Entities. Information may be shared among Fairlead Strategies LLC, Fairlead Asset Management LLC, and Fairlead Holdings LLC where reasonably necessary for legitimate business, operational, administrative, security, legal, or compliance purposes. Such sharing does not necessarily mean that every affiliated entity independently collects or maintains all categories of information described in this Policy.
Service Providers. We may disclose information to third-party service providers that support our operations, including payment processing, customer relationship management, cloud hosting, website administration, authentication, market data services, communications, cybersecurity, accounting, legal services, and regulatory compliance. Service providers are expected to handle information in accordance with applicable contractual obligations and legal requirements. Fairlead may change service providers as its business and technology evolve.
Professional Advisers. Information may be disclosed to attorneys, accountants, auditors, compliance consultants, insurers, and other professional advisers where appropriate.
Legal and Regulatory Requirements. We may disclose information when required by law, regulation, subpoena, court order, regulatory inquiry, or other lawful process.
Business Transactions. Information may be disclosed in connection with a proposed or completed merger, acquisition, restructuring, financing, sale of assets, or similar business transaction, subject to applicable confidentiality and legal requirements.
Protection of Rights and Security. We may disclose information where reasonably necessary to investigate suspected fraud, prevent security incidents, enforce agreements, protect legal rights, or address threats to individuals or systems.
Disclosures of nonpublic personal information subject to Regulation S-P will be made only as permitted by applicable law, including applicable notice, opt-out, and exception requirements. Fairlead does not authorize service providers to use subscriber information for unrelated independent purposes except as permitted by applicable law and governing agreements.
7. Cookies, Analytics, and Similar Technologies
Our websites and digital Services may use cookies, session identifiers, and similar technologies to support website functionality, authentication, security, user preferences, and performance measurement.
These technologies may collect information regarding browsers, devices, sessions, and interactions with our Services. Some technologies may be necessary for the operation of client portals, authentication systems, and other protected Services. Others may support analytics or website improvements.
Users may be able to manage certain cookies through browser settings or controls made available on our websites. Disabling essential cookies may prevent certain Services from functioning properly. Where applicable law requires consent or additional choices for particular tracking technologies, Fairlead will provide the required disclosures and controls.
8. Data Security and Confidentiality
Fairlead maintains administrative, technical, and physical safeguards reasonably designed to protect personal information against unauthorized access, acquisition, use, alteration, or disclosure.
Such safeguards may include access controls, authentication measures, vendor oversight, security monitoring, incident-response procedures, and other protective measures appropriate to the nature of the information and Services involved. Access to personal information is limited to authorized personnel, affiliated entities, and service providers with legitimate business needs.
Fairlead may use third-party technology and infrastructure providers to host, operate, authenticate, monitor, and secure its digital Services. Such arrangements are subject to applicable contractual, security, and regulatory requirements.
No electronic system, security measure, or method of transmission can be guaranteed to be completely secure. Fairlead maintains procedures for responding to suspected security incidents and will provide notifications where required by applicable law.
FS and FAM are responsible for maintaining applicable safeguards, incident-response procedures, service-provider oversight, and customer-notification practices required by Regulation S-P and other applicable laws, including applicable requirements governing unauthorized access to or use of customer information.
9. Data Retention
Fairlead retains personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, maintain business records, administer subscriptions, comply with legal and regulatory requirements, resolve disputes, and enforce agreements.
Retention periods may vary depending on the type of information, the nature of the business relationship, and applicable legal obligations. As registered investment advisers, FS and FAM may be required to retain certain books, records, communications, and client-related information for periods established by applicable securities laws and regulations.
Records documenting user acceptance of subscription terms, product-specific agreements, disclosures, and acknowledgments may be retained to establish the version accepted, date and time of acceptance, and associated account or user identity. Such records may be maintained after account closure or subscription termination where reasonably necessary for legal, regulatory, contractual, compliance, or dispute-resolution purposes.
Certain account records, analytical activity records, communications, and other information may therefore be retained after a subscription expires or an account is closed. When information is no longer required, Fairlead will take reasonable measures to delete, de-identify, or securely dispose of it, subject to applicable retention obligations.
10. Access, Correction, and Deletion Requests
Individuals may contact Fairlead to request access to, correction of, or deletion of personal information associated with them. Requests should be directed to info@fairleadstrategies.com.
Please include sufficient information for Fairlead to identify the relevant account or records. Fairlead may request additional information to verify identity or authorization before processing a request.
Requests will be evaluated in accordance with applicable law, contractual obligations, security requirements, and regulatory recordkeeping requirements. Certain information may need to be retained even after a deletion request, including records necessary for compliance, accounting, dispute resolution, fraud prevention, or other legally permitted purposes.
Where applicable law provides additional rights concerning access, correction, deletion, or other processing activities, Fairlead will evaluate and respond to requests in accordance with those requirements.
11. Marketing Communications
Fairlead may use business contact information to communicate about research publications, subscriptions, webinars, analytical tools, product updates, and related services.
Recipients may opt out of promotional email communications through an unsubscribe mechanism, where provided, or by contacting Fairlead.
Opting out of promotional communications does not necessarily prevent Fairlead from sending essential service-related messages, including billing notices, account notifications, security communications, regulatory notices, agreement updates, or other operational correspondence.
12. California and Other State Privacy Rights
Residents of certain U.S. states may have additional privacy rights under applicable law.
Depending on the relevant law and its applicability to Fairlead, these rights may include requesting access to personal information, correcting inaccuracies, requesting deletion, obtaining information about certain disclosures, or opting out of specified data processing activities.
Certain information, including information subject to applicable federal financial privacy laws, may be exempt from particular state privacy requirements. Fairlead will evaluate and respond to requests in accordance with applicable law.
Privacy requests may be submitted to info@fairleadstrategies.com. Please include "Privacy Rights Request" in the subject line.
Fairlead will not unlawfully discriminate against individuals for exercising applicable privacy rights.
13. Third-Party Websites and Services
Our websites and Services may contain links to third-party websites, applications, investment fund websites, or other resources.
Fairlead does not control the privacy practices of unaffiliated third parties and is not responsible for their independent collection, use, or disclosure of information.
Users should review the privacy policies of third-party services before providing personal information.
14. Children's Privacy
Fairlead's Services are intended primarily for professional, institutional, and adult users and are not directed toward children under the age of 13.
Fairlead does not knowingly collect personal information directly from children under 13 through its subscription Services.
If Fairlead becomes aware that such information has been collected without appropriate authorization, it will take steps consistent with applicable law.
15. Changes to This Privacy Policy
Fairlead may update this Privacy Policy periodically to reflect changes in business practices, technology, legal requirements, or the Services offered.
The current version will be published on our website with an updated revision date. Material changes will be communicated where required by applicable law.
Where applicable law requires additional notice or consent for material changes in the collection, use, or disclosure of personal information, Fairlead will provide such notice or obtain such consent as required.
16. Contact Information
For questions, concerns, or requests regarding this Privacy Policy, please contact:
Fairlead Strategies LLC
4 Greenwich Office Park, 2nd Floor
Greenwich, CT 06831
Email: info@fairleadstrategies.com
Website: www.fairleadstrategies.com
Questions concerning information processed in connection with the regulated investment advisory activities of Fairlead Asset Management LLC may also be directed to this contact for appropriate handling.