Libretto logomark

Privacy Policy

Updated: April 23, 2024

Libretto LLC (“Libretto”) is committed to safeguarding the use of your personal information that is made available to us as your internet investment adviser. Libretto and its affiliates (referred to as “we”, “our” and “us”) protect the security and confidentiality of the personal information we have and make efforts to ensure that such information is used for proper business purposes in connection with the management or servicing of your accounts.

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust. We do not sell your non-public personal information to anyone, nor does Libretto provide such information to others except for discrete and proper business purposes in connection with the servicing and management of your account and providing the services as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this privacy policy (“Privacy Policy”). Please read this Privacy Policy carefully to understand what we do.

This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. If you deal with us through an independent Registered Investment Adviser, please also review your advisor's related privacy policy.

By using libretto.io (the “Website”), you agree to the terms of this Privacy Policy.

Privacy Policy Background

Libretto LLC is a U.S. Securities and Exchange Commission (“SEC”) registered internet investment advisor and has developed this Privacy Policy as required by SEC Regulation S-P and the U.S. Gramm-Leach-Bliley Act of 1999. Regulation S-P and the U.S. Gramm-Leach-Bliley Act of 1999 require Libretto to implement policies and procedures to protect the non-public personal information of customers that Libretto collects in the normal course of conducting its business, and that Libretto shall provide a notice to such persons that describes our Privacy Policy.

Collection of Personal Information

We may collect non-public information about you (“Customer Information”) from the following sources:

Additionally, we collect personal information related to the clients of Libretto customers that is input by Libretto customers (i.e. paid subscribers) when they use the Libretto system to create strategies for their respective clients (“Client Information”). Client Information includes, but is not limited to, the following:

Unless otherwise prohibited by applicable law, Libretto may use and access Client Information as necessary to provide its services.

Automated Collection of Information

We may collect information about you automatically as you access the Website (“Usage Information”). Usage Information includes, but is not limited to, the following:

You may view and change the Customer Information associated with your account. You may contact us to ask to have your account and the Customer Information associated with it deleted or removed. Client Information may not be deleted without approval of a customer firm. Some information, such as Usage Information, may not be deleted. In addition, it may be impossible to completely delete Customer Information or Client Information due to data backups, security measures and/or compliance archiving.

How We Use Your Information

Libretto may use Customer Information, Client Information and Usage Information (collectively, “User Information”) for business purposes, including, but not limited to, the following:

Information About You That Libretto Shares

Libretto works as an organization to provide services that benefit our customers. We restrict access to your User Information to employees and agents who assist in providing the services for which you have hired Libretto. We do not sell your User Information to anyone.

We may share User Information with third parties, including, but not limited to:

You have the right to opt out of the sharing of your User Information to non-affiliated third parties and may do so via your designated support channel or by email at info@libretto.io. Please note that this may affect your experience with certain features of our Website.

If we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, User Information would be one of the assets that may be transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your User Information as set forth in this Privacy Policy.

Aggregated Data

While Libretto protects your User Information, we may use and commercialize aggregated User Information (“Aggregated Data”) for purposes of, but not limited to, data analytics, research and studies, provided that such Aggregated Data is used solely on a de-identified basis. Such Aggregated Data is anonymized and is not considered personal information or User Information under this Privacy Policy.

Information About Former Customers

Libretto does not disclose, and does not intend to disclose, User Information to non­affiliated third parties with respect to persons who are no longer our customers.

Confidentiality and Security

Our employees are advised about the firm's need to protect and respect the confidentiality of our customers' User Information. Additionally, we maintain physical, procedural, legal and electronic safeguards in an effort to protect User Information from access by unauthorized parties. Our practices include, but are not limited to, cybersecurity risk assessments (analysis of internal systems and vendors, penetration testing, etc.), user security and access controls (multifactor authentication, least privilege access, secure devices, etc.), information protection (encryption, system monitoring, intrusion detection and response, runtime defense, etc.), threat and vulnerability management (continuous analysis and monitoring, defect management, etc.) and cybersecurity incident response and recovery (backups, response and recovery plans, etc.).

Children

Minors and children should not use Libretto. By using the Website, you represent that you have the legal capacity to enter into a binding agreement.

California Residents

For accounts with a California mailing address, we will not share your User Information with a financial company for joint marketing purposes except as required or permitted by law.

International Visitors

Libretto is operated from the United States. If you are visiting the Website from outside the U.S., you agree to any processing of any User Information you provide us according to this policy.

We Will Keep You Informed

We will send you notice of our Privacy Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise our Privacy Policy, and we will provide you with a revised Privacy Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of User Information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. At all times, you may request our current Privacy Policy by contacting Libretto by email at info@libretto.io.