Privacy Policy & Notice

Last update: May 01, 2025 

The information we collect from or about you when engaging with C2, some of which may be considered sensitive information, is governed by this Notice. For purposes of this Notice, personal information, generally comprises of information that may be used to identify you. We collect the following, non-public, information to provide, enhance and optimize our service offering.

• Personal details, such as your name, unique personal identifier, current and previous address, phone numbers and email address(es). Additional information may include sensitive personal information such as date of birth, gender, marital status, details related to your family members, country of residence, immigration status and citizenship, among other.
• Government issued information, such as your social security number, state issued identifier, driver’s license number, passport number, or other government issued identifiers.
• Financial information, such as bank account(s) information, including brokerage, (most recent) tax returns and credit report, if otherwise required and necessary.
• Professional and educational information, such as employment related information, including occupation and prior work experience and/or history, role or position or title and area of expertise.

The main sources of information we collect are primary from information you (or your authorized representative) provide during the application or account creation process with (our preferred) custodian. In addition, personal information may be obtained from you (or your authorized representative) when you communicate with us, including but not limited to, when you contact us (including electronically while interacting with our website and/or mobile applications), submit inquiries, request information from us and/or provide feedback. We may also collect personal information from other (public) sources, including, but not limited to, third-party social media platforms and sites as well as government agencies, regulators, securities, futures and commodity exchanges, and self-regulatory bodies, as applicable. Furthermore, once a client and depending on the services C2 is ultimately retained, we may collect personal information based on the transactions you make. While less likely, and generally only with your consent, we may collect personal information from consumer reporting agencies.

The personal information we may disclose includes but is not limited to third parties that perform services for us and which may or may not have been disclosed in the advisory or engagement letter signed with C2. We may disclose your personal information for the purposes stated within this Notice if (a) you have provided your consent for disclosure, or (b) as otherwise permitted or required by law.

This may include disclosure of personal information to entities that help C2 to perform its services, including but not limited to, companies that may provide administrative, telecommunications, system, software, trade execution, investment managers and/or programs, payment and security clearing and/or custodial services, and that prepare and send account statements and/or transaction confirmations, and other services in connection with the operation of our business. Additionally, we may disclose information to entities that perform marketing, advertising or market research on our behalf or help us determine the effectiveness of our marketing, as well as professional service firms that help us comply with our legal and regulatory obligations and establish, enforce, and otherwise exercise our rights to defend against claims, including, for example, auditors, law firms, and consultants. Furthermore, we may disclose personal information to government, regulatory and self-regulatory entities, and law enforcement officials, which in certain cases, laws and regulations, may require us to disclose personal information. Finally, while less likely we may disclose personal information to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment, or other disposal of all or part of our business and/or assets (including accounts) for purposes of evaluating and performing proposed transaction(s).   

C2 or others acting on our behalf use cookies and similar technology, such as web beacons (also know as clear GIFs or pixel tags) or similar technologies as they may develop over time. We use these technologies to collect, use, and share information when you visit our online services or interact with us online.

Our online services and website are not knowingly directed to, solicit for, or intended for individuals under the age of 18 years . Accordingly, we do not knowingly collect information from individuals under the age of 18 years without parental consent. Furthermore, we do not knowingly sell or share information of individuals under the age of 16 years.

C2’s online sites are United States (“US”) based and may be accessed internationally on an unsolicited basis. This Notice is provided in accordance with and subject to applicable US law and if accessed outside the US, the user hereby agrees that it is subject to this Notice and personal information may be transferred, stored and/or processed in the US. By submitting personal information via our website or other means (either within or outside the US), you agree to such storage, transfer, and processing.

C2 will take reasonable steps and safeguards to protect your personal information and assure your privacy. Our employees and third party service providers will have access to personal information only on a “need-to-know” basis and which is otherwise restricted. C2 has internal policies governing the proper handling of consumer information by employees and requiring third parties to adhere to appropriate security standards with respect to such information.

C2 retains personal information in accordance with our information management policies, establishing general standards and procedures regarding the retention, handling, and disposition of our records, including personal information. Personal information is retained as long as necessary to comply with legal and regulatory requirements and may be extended if we are required to preserve personal information in connection with litigation, investigations, and proceedings.

C2 may modify or alter this Notice from time to time. We will make the latest version of this Notice accessible via our website at [website], by indicating the effective date of the Notice or changes thereto.

For questions or concerns please contact us via the [‘Contact Us’ link] on our website.