Effective: August 30, 2025
Welcome to Halzmotra! Your trust is important to us, and we’re committed to protecting the privacy and security of your personal information. The personal information you share with us helps us provide a great experience with Halzmotra. That’s why we want to keep you informed of what personal information we collect, how it’s used, and when it is shared. We are dedicated to protecting the personal information we collect from you and ensuring that it is handled with care and attention.
This Privacy Policy applies to Halzmotra Financial, Inc. and its affiliates Halzmotra Investments LLC (our registered investment adviser), Halzmotra Capital LLC (our registered broker dealer), Halzmotra Cash Management LLC (our banking services affiliate), and Halzmotra Insurance Services LLC (our insurance services affiliate). In this Privacy Policy, we refer to Halzmotra Financial, Inc. and its affiliates as “Halzmotra”.
This Privacy Policy describes how we collect, use, process, and disclose your personal information, in conjunction with your access to and use of the Halzmotra Platform(collectively, the “Services”). Our Services are available to you through a variety of platforms, including, but not limited to, www.halzmotra.com (collectively, the “Sites”),which are accessible through a variety of connected devices. The Sites are collectively referred to as the “Halzmotra Platform.”
In addition to the information provided in this Privacy Policy, Halzmotra is required by federal law to provide consumers with information regarding our collection and sharing of nonpublic personal information.
This Privacy Policy applies to visitors to the Halzmotra Platform who view publicly accessible content (“Visitors”) and customers who have signed up to access and use the Services offered by Halzmotra through the Halzmotra Platform (“Customers”).
By visiting or browsing the publicly accessible areas of the Sites, Visitors are acknowledging that they have read, understood, and agree to be legally bound by this Privacy Policy and our Terms of Use. If you do not agree to any of the terms in this Privacy Policy or the Terms of Use, you may not access or use the Sites.
By signing up, accessing, or using the Halzmotra Platform or our Services, each Customer is agreeing to the terms of this Privacy Policy, the Terms of Use.
By initiating the activation our investment products, you expressly acknowledge and agree to the following terms:
• NEOPHYTES Product : Limited to 15 activations using your account balance, A minimum balance of $1,000 required for Brokerage Tier eligibility upon the 15 activation .
• DIY Product : Limited to 2 activations using your account balance, A minimum balance of $8,000 required for Brokerage Tier eligibility upon the second activation.
• AUTOMATE Product : Limited to 5 activations using your account balance, A minimum balance of $17,000 required for Brokerage Tier eligibility upon the fifth activation.
Automatic Brokerage Tier Upgrade : Exceeding the activation limit of each of any product can triggers an automatic upgrade to the Brokerage Tier, subject to additional verification.
Associated Requirements : You agree to provide any required information (e.g., Know Your Customer [KYC] to complete the Brokerage Tier verification process, ensuring compliance with regulatory standards.
To proceed with activation, you must confirm your agreement to these terms, before getting started. Failure to meet the activation limits or minimum balance requirements may result in temporary restrictions on account functionalities, such as access to portfolio management tools, until Brokerage Tier eligibility is confirmed.
- Commitment to Security and ComplianceThe Brokerage Tier upgrade process is engineered to protect your invested assets and personal information, adhering to stringent financial regulations. Key security measures include:
Regulatory Verification: Additional verification steps, such as KYC, ensure that your account meets industry standards, safeguarding against unauthorized access and fraudulent activities.
Data Protection : Halzmotra employs advanced encryption and secure data handling protocols to protect your personal and financial information throughout the investment process.
Asset Security : The Brokerage Tier operates within a regulated framework, integrating with trusted financial exchanges to ensure the integrity and safety of your investments.
These measures enable Halzmotra to provide a secure and reliable platform, allowing you to leverage advanced features such as real-time investing, portfolio management tools, research analytics, and Individual Retirement Account (IRA) options—while maintaining compliance with global financial standards.
The following exclusions apply to this Privacy Policy:
The following exclusions apply to this Privacy Policy:
In the course of operating the Halzmotra Platform and providing the Services, we collect or receive the following categories of information, which collectively comprise “Personal Information”.
When you register to become a Customer, you will be asked to provide us with certain information about you, such as:
If you have provided us with any Personal Information, you may access, review, and/or make changes by making the changes in your registered account settings page or by contacting us at mail@halzmotra.com .
When you register to become a Customer, and at certain times following initial registration during the provision of our Services to you, we will also collect your nonpublic personal information, which means (i) any information you provide to us to obtain a financial product or service from us, (ii) any information about you resulting from any transaction involving a financial product or service between you and us, (iii) any information about a transaction, purchase or sale you are seeking to execute through the Halzmotra Platform, or (iv) any information we otherwise obtain about you in connection with providing a financial product or service to you (collectively, the “Nonpublic Personal Information”). We may also collect Nonpublic Personal Information from Visitors who are consumers of our Platform.
When you register as a Customer, you will be asked to provide information about your investment preferences and investment style, such as, your risk tolerance, time horizon, liquidity needs, investment objectives, and investment experiences (collectively, the “Investment Style Information”). Investment Style Information may be updated or modified by you following initial registration during the provision of our Services to you.
Certain features and functionalities of the Services are based on your location. In order to provide these features and functionalities while you are using a mobile device, we may, with your consent, automatically collect geolocation information from your mobile device, wireless carrier, or certain third-party service providers. Such information is collectively called "Geolocational Information." You may decline to allow us to collect such Geolocational Information, in which case Halzmotra may not be able to provide certain features or functionalities to you.
We may automatically collect or receive information about you, your use of the Halzmotra Platform, your interactions with us and our advertising and/or marketing messaging, as well as information regarding your computer or other devices used to access the Halzmotra Platform, such as:
Halzmotra does not knowingly collect or receive Personal Information from children under the age of 18, except as described in this Privacy Policy or in the privacy policies of certain Halzmotra affiliates or certain Halzmotra Sites. Generally, if a user submitting personal information is suspected of being younger than 18 years of age, Halzmotra will require the user to close their account and will not allow the user to continue using our Services. We will also take steps, as appropriate, to delete the information. Please notify us if you know of any individuals under the age of 18 using our Services, so we can determine what actions should be taken to protect these children.
Notwithstanding the above, if you establish a Halzmotra custodial account with us that is governed by the Uniform Gifts to Minors Act or the Uniform Transfers to Minors Act that is for the benefit of a child under the age of 13, only the individual establishing the account provides Personal Information to us necessary to establish the account for the child under the age of 13. Subsequent to the creation of the account, we will only collect and use Personal Information related to the child for the limited purpose of providing the Services, and except as set forth in this Privacy Policy, such information will not be shared with third parties for any purpose not required or permitted by law, including marketing.
We may also collect Personal Information about you from third-party sources, such as wallet verification services, consumer reporting agencies, unaffiliated third-party service providers, brokers, wallet databases. We may combine data we collect about you from third-party data sources with data we collect from you and may use and share such data as described in this Privacy Policy. All information we collect or receive from such third-party sources is referred to as “Third-Party Information.”
We may share information about you with third parties that Halzmotra has selected and approved for external ad distribution and ad optimization (including tailoring, behavioral or contextual targeting or retargeting, analyzing, managing, reporting, and optimizing of ads). Third parties may also use cookies, pixel tags, and other technologies to collect information about you for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive information about you from advertisers and/or their service providers, such as advertising identifiers, IP addresses, and post-conversion data. You may learn more about cookies and your ability to opt out of certain third-party advertising cookies. Even if you disable tracking, keep in mind that you may still receive interest-based advertising, including from third parties with whom your information had been previously disclosed or advertising from third parties that is not based on your interests and preferences.
Distinct from the general third-party advertising described in the above section 3.2, Halzmotra will not share your Personal Information with non-affiliated third parties that may use your Personal Information to market to you without first obtaining your opt-in consent. By providing your opt-in consent, Halzmotra may share your Personal Information with such non-affiliated third parties, and you permit such non-affiliated third parties to send marketing advertisements to you. If you have opted-in for this kind of sharing of your Personal Information, then you may: (i) choose to opt-out of such sharing; and/or (ii) request certain information regarding our disclosure of your Personal Information to such non-affiliated third parties in accordance with Section 8 below, in each case by contacting us by following the instructions in the “Contact Us” section below.
Our primary purpose in collecting information about you is to provide you with a secure, smooth, efficient, and customized experience. We may use information about you to (1) provide, understand, improve, and develop the Halzmotra Platform and Services, (2) create and maintain a trusted and safe environment (such as to comply with our legal obligations), and (3) provide, personalize, measure, and improve our advertising and marketing.
We may use Personal Information to provide, improve, and develop the Halzmotra Platform and Services, including, for example:
As part of our commitment to serving users, we launch good faith efforts to combat cybercrime, track missing assets, and recover funds for everyday users, even when incidents occur outside the halzmotra ecosystem or are caused by preventable human error. To further protect our users, we invest in user education initiatives, including halzmotra Academy, a free educational platform designed to keep users informed and help them safely navigate their crypto journey.
We may use Personal Information to create and maintain a trusted and safe environment, including, for example:
We process your Personal Information for these purposes given our legitimate interest in protecting the Halzmotra Platform and Services, to measure the adequate performance of our contractual obligations with you, and to comply with applicable laws.
We may use Personal Information to provide, personalize, measure, and improve our advertising and marketing, including, for example:
We will process your Personal Information for the purposes listed in this section, given our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you.
By using our platform, you agree to verify your wallet address, when required, by initiating a transaction from the wallet address linked to your account for the exact amount of your most recent transaction. This transaction must be made using the same wallet address you have previously used for transactions on your account. Upon successful deposit, the funds will be credited to your account balance immediately. You are required to upload the payment voucher or transaction receipt through the KYC verification form to complete the verification process. This step ensures the security and legitimacy of your account and transactions.
The security of your Personal Information is of utmost importance to us. Halzmotra handles sensitive financial customer data, so we’ve taken steps to secure critical systems and information. For example, we use encryption to protect and secure all of your information, from personal data (like your Social Security number) to your transaction history. We take commercially reasonable technical, administrative, and physical safeguards to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.
If you know or have reason to believe that your Personal Information or Halzmotra account has been stolen, misappropriated, or otherwise compromised, or if you receive an unsolicited email or other electronic communication that appears to be from Halzmotra but you suspect it may be from some other source or fraudulent, please contact us by following the instructions in the “Contact Us” section below.
We will retain your Personal Information for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy or subsequently authorized. We will also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If your customer relationship with Halzmotra ends, we will not destroy your Information unless required or permitted by law. We will continue to treat your Personal Information in accordance with this Privacy Policy and applicable laws.
Information connected to you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights that are commercially valuable to Halzmotra, such as statistics of the use of the Services.
Our global privacy framework is inspired by the European Union’s General Data Protection Regulation (GDPR), which is widely considered one of the strictest and most comprehensive frameworks globally. A big part of our users hold several key rights. These include :
Right to access: You have the right to obtain confirmation that your personal data are processed and to obtain a copy of it as well as certain information related to their processing.
Right to rectify: You can request the rectification of your personal data which are inaccurate, and also add to them. You can also change your personal data in your account at any time.
Right to delete: You can, in some cases, have your personal data deleted.
Right to portability: In some cases, you can ask to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format, or, when this is possible, to have us communicate your personal data on your behalf directly to another data controller.
Right to contest to a decision based solely on automated processing: You have the right to require that decisions be reconsidered if they are made solely by automated means, without human involvement. We use automated tools to make sure that you are eligible to be our customer taking into account our interests and legal obligations; if these automated tools indicate that you do not meet our acceptance criteria, we will not onboard you as our customer.
Temporary restrictions on account functionality shall remain in effect for a period of three (3) weeks from the date of implementation. Upon the conclusion of this period, full access to all account features will be automatically reinstated, provided no further violations have occurred. Users will receive a notification via email confirming the restoration of full account functionality.
You have choices on the messages you choose to receive.
Effective Feb 20, 2023, the California Privacy Rights Act (“CPRA”), in addition to the rights already established under the California Consumer Privacy Act of 2020 (“CCPA”) (collectively referred to in this notice as “CPRA”), allows California residents, upon a verifiable consumer request and subject to applicable exemptions, to request that we give you access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that we have collected about you, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. Where CPRA is applicable, California residents may also have the right to submit a request for deletion of information under certain circumstances. Please note that the CPRA does not apply to non-public personal information collected by financial institutions governed by certain federal regulations. As a result, the CPRA does not apply to most of the personal information that Halzmotra collects from you as a customer.
Halzmotra will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you services, charge you different prices for services, prevent you from applying for future employment with Halzmotra, or provide you a different level or quality of services. To submit a data request, please contact us by following the instructions in the “Contact Us” section below. Please note that you may be required to verify your identity before further action is taken. Please be prepared to provide us with information such as: your first and last name, the last four digits of your Social Security number, and proof of California residency to verify your identity, along with identifying with specificity which CPRA right you wish to exercise. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester's valid government-issued identification, and the authorized agent's valid government-issued identification.
We do not sell Personal Information to third parties. We do not sell the Personal Information of California residents that are less than 16 years of age, unless the resident (in the case of residents between 13 and 16 years of age) or the resident’s parent or guardian (in the case of residents who are less than 13 years of age) has affirmatively authorized the sale of the resident’s Personal Information. We do allow third parties to collect personal information through our Service and share personal information with third parties for the business purposes described in this Privacy Policy, including, without limitation, advertising and marketing on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices.
In the last 12 months, we collected certain categories of personal information including, but not limited to: identifiers (such as name, email address and IP address), Internet or other electronic network activity information (such as engagement with promotional messages and ads). For more details about the categories of information we collect and the categories of sources of this information, please see the “Information We Collect or Receive” and the “Sources of Personal Information” sections above. We share this information with the categories of third parties described in the “How the Information Is Used” section above.
California law permits consumers who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information, disclosed to those third parties. Stash does not share Personal Information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent the disclosure of your Personal Information to third parties for their direct marketing purposes by withholding or withdrawing consent.
A Smart Portfolio is a pre-built, diversified investment portfolio designed to follow a specific strategy. It allows investors to access a wide range of assets and markets through a single investment, simplifying the process. These portfolios are typically managed by experts, offering a convenient and potentially less time-consuming way to invest compared to building a portfolio from scratch, while still aiming to deliver strong, diversified returns.
Investing in a Smart Portfolio offers several advantages, particularly for investors seeking a streamlined and professionally managed approach.
Below is a clear explanation of the key benefits :
1. Diversification : Smart Portfolios are designed to include a variety of assets (e.g., stocks, bonds, ETFs) across different sectors, industries, or regions. This diversification helps spread risk, reducing the impact of poor performance in any single asset or market.
2. Professional Management : These portfolios are typically managed by financial experts who monitor and adjust the investments to align with the portfolio’s strategy. This expertise ensures informed decision-making without requiring investors to have deep market knowledge.
3. Convenience and Time Efficiency : Smart Portfolios are pre-built, eliminating the need for investors to research, select, and manage individual assets. This saves time and effort, making it ideal for those with limited time or expertise to build a portfolio from scratch.
4. Accessibility : With a single investment, investors gain exposure to a broad range of assets and markets, which might otherwise require significant capital or expertise to access individually.
Minimum Balance Requirements for Smart Portfolio
The minimum investment amount for a Smart Portfolio varies depending on the selected product :
- DIY : $6,000
- Automate : $15,000
- Robo : $20,000
These minimums are set to ensure your account has sufficient funds to open all necessary positions within the portfolio.
Smart Portfolios require higher minimum investments because they function like a team of investors working simultaneously on your behalf, managing multiple underlying positions to optimize your investment strategy.
Intelligent Investing for Ambitious Goals
Our Smart Portfolio and Automated Investing solutions combine advanced technology with seamless user experience, offering you the flexibility to grow your capital with confidence. Whether you're starting your investment journey or aiming for sophisticated strategies, activating Smart Portfolio unlocks the full potential of Automated Investing, delivering smarter, more dynamic portfolio management.
The Smart Portfolio is a powerful, AI-driven solution designed to optimize your investments with precision and agility. Built on advanced algorithms, it adapts to market conditions in real-time, ensuring your portfolio aligns with your financial objectives and risk tolerance while maximizing returns.
Automated Investing : When you activate Smart Portfolio, your account is automatically upgraded to our Automated Investing tier at no additional setup cost. Automated Investing forms the backbone of our platform, using proven algorithms to build and manage a diversified portfolio tailored to your goals.
Defining Characteristics ;
- Dynamic Asset Optimization : AI-powered adjustments respond to market trends, such as sector rotations or volatility hedging, to enhance growth potential.With Smart Portfolio, you gain professional-grade management at a competitive return of 63% on a biweekly [2 weeks], delivering the potential for superior performance through intelligent automation.
This seamless integration ensures your Smart Portfolio inherits all the strengths of Automated Investing while adding advanced, AI-driven enhancements for greater control and optimization.
Effortless Upgrade: Activate Smart Portfolio, Unlock Automated Investing Tier.Supercharging your investment strategy is simple. With a single click in your account dashboard, you can activate Smart Portfolio and instantly upgrade to the Automated Investing tier. This smooth transition ensures your portfolio evolves without interruption, combining the simplicity of Automated Investing with the sophisticated features of Smart Portfolio.
Why Choose Smart Portfolio?
- No Lock-In Periods: Switch back to basic Automated Investing anytime, giving you full flexibility.
- Trusted and Secure: Our FCA-regulated platform offers 99.9% uptime and robust compliance for peace of mind.
- Risk-Free Trial: New Smart Portfolio users enjoy a 14-day free trial, experiencing the power of advanced automation.
Learn more about how Halzmotra keeps you safe, plus additional ways you can keep your Halzmotra account secure.
From your investments to your cash, you can feel confident in the security of your money on Halzmotra.
When you use Halzmotra, your information is encrypted and stored on secure servers, and your funds and securities are held with your security in mind.
Your current investments are covered up to a maximum of $200,000 total, including $150,000 in both interest and deposit wallet balances through the Securities Investors Protection Corporation (SIPC).For uninvested funds, your Halzmotra account is enrolled in something called the Apex FDIC-insured Sweep Program. And here are the details:
Halzmotra accounts are enrolled in an interest-bearing Federal Deposit Insurance Corporation (FDIC) insured Sweep Program (“Sweep Program”) offered through our clearing firm, Apex Clearing Corp. Uninvested Cash in your Halzmotra account will automatically be transferred into the Sweep Program and will earn interest based on the amount and duration of the investment and applicable interest rates. Deposits to the Sweep Program are covered by FDIC insurance up to the $150,000 limit per customer at each FDIC-insured bank that participates in the Sweep Program.
Your Halzmotra investment account is protected by the following security features and policies.
• Security alert texts :
We've enabled email, text, and online notifications for certain transactions to inform you in real time about events that can have a security on your halzmotra account.
• Customer verification, restricted customer data access :
No matter where you visit us, we always verify your identity before allowing access to your accounts. Employees only see your data on a "need-to-know" basis, and we monitor all transactions for suspicious or unusual behavior. For your health safety.
• Security at our offices :
We vigilantly monitor all work areas in order to prevent theft or unauthorized use of your sensitive information. In addition, authorized personnel can only enter work areas through use of a security badge.
• Extra login security using multi–factor authentication (MFA) :
To keep your accounts safer, we offer MFA as an extra layer of security that can be added to your account to restrict someone from logging in — even if they have access to your username and password.
Learn more about our security features.
✓ 256-bit encryption : We use encryption to protect and secure all of your information, from personal data (like your social security number) to your transaction history.
✓ Transport Layer Security (TLS) : Our mobile and web applications use the latest Transport Layer Security protocol to protect your information when communicating with Halzmotra.
✓ Biometric recognition : You have the option to use biometric recognition (such as a fingerprint or facial scan) to access your account.
✓ Access control : Halzmotra uses session end-timers and log-in thresholds to prevent unauthorized access to your account. Halzmotra also offers two-factor authentication to all active investment account customers for additional security.
✓ Cutting-edge technology : We constantly monitor the latest security technologies to make sure that our systems are up to date and comply with industry best practices.
How to improve your password security :
• Do not create passwords that can be easily guessed, such as your birthdate.
• Do not use common names and/or numerical sequences as passwords. Examples include: pets, children, social security number, name, address, phone number, username, social media information, 1234, 1111, etc.
• Do not share your passwords with anyone.
• Avoid using the same password for multiple institutions/accounts/sites.
• Always use strong passwords. The most secure passwords are long (12+ characters) and combine uppercase and lowercase letters, numbers, and special characters (!?#@).
- Sign into your Halzmotra account via halzmotra.com
- Only visit our website through our link
- Do not click links or open attachments from unknown parties.
- Be suspicious of emails from people or companies that are unfamiliar.
- To protect your Halzmotra account, always log out after a session and close your browser.
- Use two-factor authentication (also known as multi-factor authentication) if they are available to you.
1. Account Restrictions for Unusual Activity :
To protect the integrity and security of your account, we continuously monitor transactions for potential unauthorized access or suspicious activity. If we detect an unusual transaction, such as one originating from an unrecognized IP address or involving an outgoing transaction (e.g., internal transfer, withdrawal, or other account activity), we may temporarily restrict certain account functions. These restrictions are implemented to prevent unauthorized access and ensure your account's safety.
2. Verification Requirements :
In the event of a temporary account restriction due to an unusual transaction, you will be required to verify your identity and wallet address to restore full account access. This verification process is mandatory and includes, but is not limited to, the following steps:
• Logging into your account and completing the identity verification prompts.
• Confirming ownership of the wallet address associated with the transaction.
• Reviewing recent account activity and reporting any unauthorized transactions to our support team.
These measures are designed to safeguard your account and prevent fraudulent activity. Failure to complete the verification process within the specified timeframe may result in prolonged restrictions or additional security measures.
3. Notification and Action :
Upon detection of an unusual transaction, we will notify you via email or through your account dashboard with details of the transaction (e.g., date, time, and nature of the activity). You will be provided with clear instructions to complete the verification process. For further assistance, you may contact our support team.
4. User Responsibilities :
You are responsible for maintaining the security of your account, including using strong passwords, enabling two-factor authentication, and promptly reporting any unrecognized activity. We strongly recommend regularly reviewing your account settings and transaction history to ensure all activities are authorized.
5. Our Commitment to Security :
We prioritize the protection of your account and personal information. Temporary restrictions and verification requirements are implemented solely to mitigate risks of unauthorized access or fraudulent transactions. We apologize for any inconvenience caused and appreciate your cooperation in maintaining a secure environment.
We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on the Halzmotra Platform prior to the change becoming effective, or as otherwise required by law. Your continued access to or use of the Halzmotra Platform after we make any changes to this Privacy Policy will be subject to the revised Privacy Policy.