HAMILTON CAPITAL, LLC


Privacy Policy

Hamilton Capital, LLC (“Hamilton Capital,” “we,” “us,” or “our”) is an investment adviser registered with the Securities and Exchange Commission (“SEC”). We are committed to protecting the privacy of individuals who visit our website located at www.HamiltonCapital.com (the “Site”).

This Website Privacy Policy explains what information we collect through the Site, how we use and share it, your rights and choices regarding that information, and how to contact us. This policy applies to general visitors to the Site, including prospective clients and members of the public. It does not apply to services provided to existing investment advisory clients, which are separately governed by our Regulation S-P Privacy Notice.

By using the Site, you acknowledge that you have read and understood this policy.

Information We Collect

A. Information You Provide Voluntarily
We collect information you choose to provide when you:

  • Submit a contact or inquiry form
  • Request information about our services
  • Register for a webinar or event
  • Subscribe to email communications
  • Respond to a survey or questionnaire

The types of personally identifiable information (“PII”) we may collect in these contexts include your name, email address, phone number, city, employer, and any other information you choose to include in your message or form submission.

B. Information Collected Automatically
When you visit the Site, we and our service providers may automatically collect certain technical and usage information, including:

  • Anonymized usage data generated from your interactions with our website.

This information is collected using cookies and similar tracking technologies, as described in Section 4 below. It does not, by itself, identify you personally, but may be combined with other information that does.

C. Information We Do Not Collect
We do not knowingly collect sensitive personal information through the Site, such as Social Security numbers, financial account numbers, or health information. Do not submit such information through any Site contact form or inquiry.

How We Use Your Information

Hamilton Capital collects your data so that we can:

  • Respond to your inquiries and requests
  • Manage your account
  • Send you event confirmations, reminders, and follow-up communications
  • Administer and improve the website, including analyzing usage patterns and diagnosing technical problems
  • Contact you by email or telephone calls regarding updates or information related to your relationship with us.
  • Comply with applicable legal and regulatory requirements
  • Protect the security and integrity of the Site

We do not use Site-collected information for automated decision-making or profiling that produces legal or similarly significant effects.

Cookies and Similar Technologies

We use cookies and similar technologies (such as web beacons and pixel tags) to operate and improve the Site. Cookies are small text files stored on your device that allow us to recognize your browser across visits and gather usage information.

Types of Cookies We Use

  • Essential Cookies: Required for the Site to function. Disabling them may impair Site functionality.
  • Analytics Cookies: Help us understand how visitors interact with the Site (e.g., which pages are most visited, how long visitors stay). We may use services such as Google Analytics for this purpose.
  • Preference Cookies: Remember your settings and preferences across visits.
  • Marketing Cookies: May be used to deliver relevant content or measure the effectiveness of communications. We will request your consent before placing non-essential marketing cookies where required by applicable law.

Your Cookie Choices
Most browsers allow you to refuse or delete cookies through their settings. Doing so may affect Site functionality. You may also opt out of Google Analytics data collection by installing the Google Analytics Opt-Out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

Do Not Track Requests
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites.

How We Share Your Information

We do not sell your personally identifiable information to third parties. SMS opt-in data and consent are not shared with third parties or affiliates. We do not disclose your PII for third-party direct marketing purposes without your consent.

We may share your information in the following limited circumstances:

  • Service Providers: We may share information with vendors and service providers who assist us in operating the Site, hosting content, delivering email communications, conducting analytics, or providing webinar platforms. These parties are contractually obligated to use your information only as necessary to provide services to us and to maintain appropriate security measures.
  • Legal and Regulatory Requirements: We may disclose information if required to do so by law, regulation, court order, or in response to a lawful request by a governmental authority, or if we believe disclosure is necessary to protect the rights, property, or safety of Hamilton Capital, our clients, or others.
  • Professional Advisers: Consistent with Regulation S-P (§§ 248.13–248.15), we may disclose information to attorneys, accountants, auditors, and compliance assessors under appropriate confidentiality obligations.
  • Business Transfers: In the event of a merger, acquisition, asset sale, or similar corporate transaction, your information may be transferred to the successor entity, subject to the same privacy commitments described in this policy.

We require all third-party recipients of your information to maintain appropriate data security measures and to use your information only for the purposes for which it was disclosed.

Data Retention

We retain personal information collected through the Site for as long as necessary to fulfill the purposes described in this policy, comply with applicable legal and regulatory obligations (including applicable books-and-records requirements under the Investment Advisers Act of 1940), and resolve disputes. When information is no longer needed, we dispose of it in a manner designed to protect against unauthorized access, consistent with our data disposal obligations under Regulation S-P.

Security

Hamilton Capital maintains a written information security program that includes administrative, technical, and physical safeguards designed to protect personally identifiable information from unauthorized access, use, disclosure, alteration, or destruction. These measures include, but are not limited to, encryption of data in transit, access controls, and employee training on data handling.

In the event of a security incident involving your sensitive personal information, we will notify affected individuals in accordance with applicable federal and state law, including our obligations under amended Regulation S-P.

No transmission of information over the internet is completely secure. While we work to protect your information, we cannot guarantee the security of information you transmit to us through the Site.

Children’s Privacy

The Site is not directed to children under the age of 13, and we do not knowingly collect personally identifiable information from children under 13. If you believe we have inadvertently collected information from a child under 13, please contact us and we will promptly delete it.

Notice to California Residents

If you are a California resident, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA/CPRA”), provides you with specific rights regarding your personal information.

Categories of Information Collected
In the preceding 12 months, we have collected the following categories of personal information from Site visitors: identifiers (name, email, IP address); internet or other electronic network activity information (browsing behavior on the Site); and geolocation data (city-level, derived from IP address).

Your California Rights
Subject to certain exceptions, California residents have the right to:

  • Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of that information, the business purposes for which it was collected, and the categories of third parties with whom it was shared.
  • Delete: Request deletion of personal information we have collected from you, subject to certain exceptions.
  • Correct: Request correction of inaccurate personal information we maintain about you.
  • Opt Out of Sale or Sharing: We do not sell your personal information or share it for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA.
  • Limit Use of Sensitive Personal Information: We do not use or disclose sensitive personal information beyond the purposes authorized by the CCPA/CPRA.
  • Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

How to Exercise Your California Rights
To submit a California privacy request, contact us. We may need to verify your identity before processing your request. You may designate an authorized agent to make a request on your behalf.

Notice to Nevada Residents

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt out of the “sale” of certain personal information. We do not sell personal information about Nevada residents as defined under Nevada law. If you have questions about our compliance, please contact us.

Notice to European Economic Area, United Kingdom, and Swiss Residents

If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, this section applies to you in addition to the rest of this policy.

Legal Basis for Processing
We process your personal data on the following legal bases:

  • Legitimate Interests: Operating and improving the Site, responding to inquiries, and conducting analytics – where those interests are not overridden by your rights and interests.
  • Consent: Where we rely on your consent (e.g., for non-essential cookies or marketing emails), you may withdraw it at any time without affecting the lawfulness of prior processing.
  • Legal Obligation: Where processing is necessary to comply with a legal obligation.

International Data Transfers
If you are located in the EEA, UK, or Switzerland, your personal data will be transferred to and processed in the United States. The United States may not provide a level of data protection equivalent to that in your jurisdiction. Where required, we rely on appropriate safeguards for such transfers, including Standard Contractual Clauses approved by the European Commission, or other mechanisms recognized under applicable law.

Your EEA/UK Rights
Subject to applicable law, you may have the right to access, rectify, erase, restrict, or object to the processing of your personal data, the right to data portability, and the right to lodge a complaint with a supervisory authority. To exercise these rights, contact us using the information in Section 13.

Updates to This Policy

We may update this Website Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the “Last Updated” date at the top of this policy and, where appropriate, provide additional notice (such as a prominent statement on the Site). Your continued use of the Site following any update constitutes your acceptance of the revised policy.

We encourage you to review this policy periodically to stay informed about our information practices.

Contact Information

If you have questions, concerns, or requests regarding this Website Privacy Policy, or wish to exercise any rights described herein, please contact:

Hamilton Capital, LLC
Tony Strotman, Director of Compliance
5025 Arlington Centre Blvd., Suite 300
Columbus, OH 43220
Email: [email protected]
Phone: (614) 273-1000