Updated: July 14, 2026
Elm Partners Management LLC (“Elm Partners,” “we,” “our,” or “us”) is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, share, and protect information about visitors to our website and individuals who interact with us, and explains your rights with respect to that information. This policy is provided in accordance with applicable federal and state privacy laws, including the Gramm-Leach-Bliley Act (GLBA), SEC Regulation S-P, the UK General Data Protection Regulation (UK GDPR), and applicable state privacy statutes.
Elm Partners does not sell your personal information to any third party.
Information We Collect
We collect the following categories of information:
Information you provide directly:
| Required Information | Optional Information |
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Information collected automatically:
When you visit our website, we may collect certain technical information, including IP address, browser type, device identifiers, pages visited, and referring URLs. This information is collected via cookies and similar tracking technologies. For details, please see our Cookie Policy.
Information collected from investors:
If you invest with us, we collect additional financial and identity information as described in the Investor-Specific Privacy Notice contained in our Form ADV Part 2A/2B.
When We Collect Information
We collect information through:
- Website contact and message form submissions
- Research and newsletter subscriptions
- Investment applications and onboarding
- The Missing Billionaires and other content requests
- Interactive tools and game submissions
- Ongoing email and phone communications
- In-person and online meetings
We may utilize an AI meeting assistant for automated meeting prep, to capture meeting notes, and for action items and follow-ups from client meetings. The AI meeting assistant may have access to nonpublic personal information about our clients to assist with these tasks but does not create audio or video recordings of the meetings.
How We Use Your Information
We use collected information to:
- Send research updates, blog posts, and newsletters you have subscribed to
- Respond to inquiries and provide information about Elm’s services
- Process investment applications and manage client relationships
- Improve products and services
- Maintain records of communications via our customer relationship management (CRM) platform
- Comply with legal and regulatory obligations
- Detect and prevent fraud or security incidents
We do not use your information for automated decision-making or profiling that produces legal or similarly significant effects.
How We Share Your Information
We do not sell your personal information. We may share information in the following limited circumstances:
Service providers:
We share information with third-party vendors who are needed to support our business operations. Including services such as our CRM platform and its integrated third-party plugins, notetaking tools, email service providers, and our custodial and administrative partners (for investors only). These and other providers are contractually required to protect your information and use it only for the agreed upon purposes. Please see the GLBA Opt-Out Notice below regarding your right to opt out of certain sharing with third-parties.
Custodians and administrators (investors only):
Non-public financial information and other PII may be shared with institutions we use for custody and administration. See our Form ADV Part 2A/2B for details.
Legal and regulatory requirements:
We may disclose information as required by law, court order, or regulatory authority, including the SEC and FINRA.
Business transfers:
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, subject to the same privacy protections.
GLBA Opt-Out Notice
The Gramm-Leach-Bliley Act (GLBA) gives you the right to limit certain sharing of your personal information with nonaffiliated third parties. This notice describes the sharing that requires your opt-out right and how to exercise it.
What we share and with whom:
Certain information you provide to us — such as your name, email address, interaction and communication history — may be shared with or processed by third-party service providers that are necessary to support our operations. These providers are not affiliated with Elm Partners and are contractually required to use your information only for the services they provide to us.
Your right to opt out:
You may direct us to not share your personal information with third parties beyond what is necessary to service your relationship with Elm Partners.
How to opt out:
To exercise this right, send an email to info@elmwealth.com with the subject line “[Your Name] – GLBA Opt-Out.” We will process your request within 30 days.
Effect of opting out:
Opting out will not affect our ability to provide you with investment management services, research communications, or any other services you have requested from Elm Partners. It will only limit the sharing described above.
Joint marketing:
We do not share your personal information with nonaffiliated third parties for joint marketing purposes.
If you are a current or former client, this opt-out right applies to you. If you are a website visitor or research subscriber, we encourage you to exercise this right if you have any concern about your data being processed by third-party plugins.
Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this policy, maintain our business records, and comply with applicable legal and regulatory requirements. For current and former clients, we retain records in accordance with SEC recordkeeping rules, generally a minimum of five years. You may request information about our retention practices by contacting us at the address below.
How We Protect Your Information
We maintain a written information security program and implement administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, use, or disclosure. These measures include:
- Limiting employee access to personal information on a need-to-know basis
- Training employees on privacy and data security obligations
- Requiring contractual data protection commitments from service providers
- Maintaining an incident response program to detect, contain, and remediate security events
Security incident notification:
In the event we experience a security breach that compromises your personal information, we will notify affected individuals as soon as reasonably practicable, and no later than 30 days after we determine that a breach has occurred, in accordance with SEC Regulation S-P and applicable state law. Where required by applicable law — including Massachusetts Chapter 93H — we will also notify the relevant state regulatory authority (such as the Massachusetts Attorney General and the Office of Consumer Affairs and Business Regulation) concurrently with or prior to notifying affected individuals. Where appropriate, we will also notify and cooperate with law enforcement authorities, including federal and state agencies, in connection with any security incident.
Your Privacy Rights
Depending on your state or country of residence, you may have the right to:
- Access the personal information we hold about you
- Correct inaccurate or incomplete information
- Delete your personal information (subject to legal and regulatory retention requirements)
- Opt out of certain sharing as described in the GLBA Opt-Out Notice above
To exercise any of these rights, contact us at info@elmwealth.com. Please include your full name and the nature of your request in the subject line (e.g., “[Your Name] – Information Request” or “[Your Name] – Delete My Information”). We will respond within 45 days.
California Residents (CCPA / CPRA)
Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have additional rights, including:
- The right to know what categories of personal information we collect and how it is used and shared
- The right to opt out of the sale or sharing of personal information (we do not sell or share personal information for cross-context behavioral advertising)
- The right to correct inaccurate personal information
- The right to limit the use of sensitive personal information
- The right to non-discrimination for exercising your privacy rights
To submit a request, contact us at info@elmwealth.com.
UK and EU Residents – UK GDPR
If you are located in the United Kingdom or European Union, the UK General Data Protection Regulation (UK GDPR) or EU GDPR applies to the processing of your personal information. This section provides the additional disclosures required under those laws.
Data Controller:
Elm Partners Management LLC, 50 S. 16th Street, FL 18 Suite C, Philadelphia, PA 19102, USA (info@elmwealth.com) is the data controller responsible for your personal information.
Legal Basis for Processing:
We process your personal information on the following legal bases:
- Legitimate interests (Article 6(1)(f)): For research and newsletter communications sent to subscribers and prospective clients, and for maintaining CRM records of our interactions with you. Our legitimate interest is in building and maintaining relationships with individuals interested in investment education and Elm’s services.
- Contractual necessity (Article 6(1)(b)): For processing your information in connection with an investment management agreement or client onboarding.
- Legal obligation (Article 6(1)(c)): For retaining records as required by applicable financial regulations, including FINRA and SEC recordkeeping rules.
- Consent (Article 6(1)(a)): Where we rely on your consent (e.g., for certain cookie categories), you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.
Your Rights Under UK / EU GDPR:
In addition to the rights described above, UK and EU residents have the right to:
- Data portability: Receive a copy of your personal information in a structured, commonly used, machine-readable format, and to transmit it to another controller where processing is based on consent or contract
- Restrict processing: Request that we limit how we use your information in certain circumstances
- Object to processing: Object to processing based on legitimate interests. Where you object to processing for direct marketing purposes, we will stop immediately and without needing to assess your grounds for objection
- Withdraw consent: Where processing is based on consent, withdraw that consent at any time
International Data Transfers:
Elm Partners is based in the United States. When we receive personal information from UK or EU residents, your data is transferred to and processed in the United States. We rely on Standard Contractual Clauses (SCCs) — pre-approved contractual safeguards issued by the European Commission and adopted for UK transfers — as the legal mechanism for these international data flows as needed. Please contact us at info@elmwealth.com if you would like more information about the safeguards in place for your data, including a copy of the applicable SCCs.
Right to Lodge a Complaint:
If you are a UK resident and believe we have not handled your personal information in accordance with the UK GDPR, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at ico.org.uk. If you are an EU resident, you may lodge a complaint with your local supervisory authority.
Data Breach Notification (UK/EU GDPR):
Where a security breach is likely to result in a risk to the rights and freedoms of UK or EU residents, we will notify the relevant supervisory authority (such as the ICO for UK residents) within 72 hours of becoming aware of the breach, as required under the UK GDPR. Where the breach is likely to result in a high risk to affected individuals, we will also notify those individuals without undue delay.
Children’s Privacy
Our website and services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us at info@elmwealth.com and we will promptly delete it.
Changes to This Policy
We may update this Privacy Policy periodically. If changes are material, we will notify you by email or by posting a prominent notice on our website prior to the changes taking effect. The date at the top of this policy reflects when it was last revised.
Questions or Concerns
For questions about this policy or to exercise your privacy rights, contact us at:
Elm Partners Management LLC
50 S. 16th Street, FL 18 Suite C
Philadelphia, PA 19102
info@elmwealth.com
+1 (888) 676-3148