Effective 25 October 2026
Privacy notice
This notice explains how Holocron Holdings LLC, a registered investment adviser in Nevada (CRD 343224), collects, uses and shares personal information through holocronholdings.com. If you become a client, you will also receive our privacy notice for clients, required by the Gramm-Leach-Bliley Act, with your advisory agreement.
What we collect
- Account details: your email address and password. The password is stored only as a secure hash that we cannot read.
- Multi-factor authentication: a record of the authenticator app you enroll. We never receive codes in advance.
- Consent records: the versions of this notice and our terms you agree to, with the date and time, your IP address and your browser details.
- Questionnaire answers: whether you are seeking information about our strategies, your investable net worth and annual income ranges, investment objective, time horizon and your confirmations about the hypothetical performance disclosure, with the version of the disclosure you saw, the date and time, your IP address and browser details, and the resulting access decision.
- Technical data: IP addresses, browser type and pages requested, which our hosting providers log to run and secure the website, and the signals Cloudflare's bot check reads when you sign up or log in.
We collect this information from you directly and from your browser. We do not collect your name, postal address, phone number, Social Security number or account numbers through the website.
How we use it
To create and secure your account; to decide, as securities regulations require, whether hypothetical performance is relevant to you before we show it; to keep the records investment advisers must keep; to tell the firm when someone completes the questionnaire; to answer your requests; and to protect the website against fraud and abuse. We do not use it for advertising.
Who we share it with
We do not sell or rent personal information, and we do not share it with anyone for their own marketing. We share it only with service providers that run the website for us and may use it only for that purpose:
- Supabase, which stores accounts and records;
- Vercel, which hosts the website;
- Cloudflare, which provides the Turnstile bot check on sign-up and log-in; and
- Resend, which delivers the firm's notification emails.
We may also disclose information to securities regulators and other authorities when the law requires it, in an examination, or to protect our rights, and to a successor if the firm's business is transferred.
Cookies, tracking and Do Not Track
The website uses cookies only to keep you signed in, and the dashboard stores your portfolio settings in your own browser. We use no analytics, advertising or social media trackers, and we do not allow other parties to collect information about your activity across websites through ours. Cloudflare's bot check runs on the sign-up and log-in forms only, as a security measure. Because we do no cross-site tracking, the website does not respond differently to browser “Do Not Track” signals.
How long we keep it
Records of consents, questionnaire answers, disclosure acceptances and access decisions are kept for at least five years, as investment adviser record-keeping rules require (Nevada NAC 90.3879, and similar rules in other states), and cannot be deleted during that period, even if you close your account. Hosting logs are kept for shorter periods set by our providers.
How we protect it
Access to restricted areas requires an authenticator app; information is encrypted in transit; records are protected by database access rules and cannot be altered once written; and only the firm's authorized staff can see questionnaire answers. No system is perfectly secure, and we will notify you of a security breach affecting your information as the law requires.
Your choices
You can ask to see the personal information we hold about you, ask us to correct it, or close your account, by writing to the address below. Records we are required to keep will be retained as described above. Some states give their residents further rights; contact us and we will honor those that apply to you.
Children
The website is not directed to anyone under 18, and we do not knowingly collect information from them.
Changes
We will post any change to this notice on this page with a new effective date. Consent records show which version each person agreed to.
Contact
Privacy questions and requests can be sent to dev@holocronholdings.com or 844-733-2783.