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Privacy Policy

How Eshel Spring LLC collects, uses, protects, and shares your information

Last updated: January 2025

This Privacy Policy explains how Eshel Spring LLC ("we," "our," or "us"), operating the AI-powered discretionary investment platform Eshel Bot, collects, uses, protects, and shares client information. This policy is intended to comply with SEC Regulation S-P and other applicable U.S. securities laws.

This policy is subordinate to and integrated with:

  • Form ADV Part 2A – Firm Brochure
  • Client Advisory Agreement
1

Introduction

Eshel Spring LLC is an SEC-registered investment adviser providing discretionary portfolio management via Eshel Bot. Clients grant Eshel Bot authority to execute trades on their behalf based on pre-agreed investment parameters.

We respect your privacy and are committed to protecting your Nonpublic Personal Information (NPI), as defined under Regulation S-P, and maintaining the confidentiality, security, and integrity of all client data.

2

Information We Collect

We collect information necessary to provide discretionary investment advisory services:

2.1 Information Provided by Clients:

  • Full name, email, and account credentials
  • Brokerage account information, including Alpaca API credentials
  • Investment objectives, risk tolerance, and account settings
  • Compliance acknowledgments, consents, and authorization for options trading

2.2 Nonpublic Personal Information (NPI)

As defined under Regulation S-P, NPI includes personally identifiable financial information obtained from:

  • Account applications or agreements
  • Trade instructions and transaction history
  • Risk tolerance, preferences, and investment objectives

2.3 Information Collected Automatically:

  • Device identifiers, IP addresses, OS, and app version
  • Usage logs, error reports, system diagnostics
  • Trade execution metadata (timestamps, order status, confirmations)

2.4 Information Collected for AI/Model Use:

  • Data may be used in algorithmic decision-making and model improvement
  • Data use is restricted to aggregated, anonymized analysis unless client consents to additional testing
3

Use of Information

Client information is used to:

  1. 1Execute discretionary trades and maintain accounts
  2. 2Monitor portfolios and enforce risk parameters
  3. 3Support platform functionality and client support
  4. 4Conduct system audits and regulatory reporting
  5. 5Improve AI model performance while safeguarding NPI
4

Sharing of Information

4.1 Permitted Sharing Under Regulation S-P

We may share NPI only with:

  • Integrated brokers (e.g., Alpaca) for trade execution
  • Infrastructure and security vendors for operations, encryption, and monitoring
  • Legal or regulatory authorities as required by law

4.2 Prohibited Sharing

  • We do not sell, rent, or trade client information for marketing purposes
  • Third-party data use is strictly limited to supporting services approved under our compliance policies

4.3 Third-Party Broker Fees Disclosure

  • Clients are responsible for all broker and API fees, including Alpaca API transaction, exchange, and margin fees
  • Eshel Spring LLC does not collect or offset these fees
5

Client Privacy Rights

Under U.S. securities laws, current and former clients have the right to:

  • Access their personal and account information
  • Request corrections or updates to inaccurate information
  • Opt out of certain information sharing not required for trade execution or regulatory compliance
  • Obtain a copy of this Privacy Policy upon request

Requests should be submitted to:

Email: info@eshelbot.com

Phone: (781) 518-8660

6

Cybersecurity, Incident Response & Breach Notification

Eshel Spring LLC implements industry-standard safeguards including:

  • Encryption of data in transit and at rest
  • Role-based access controls and multi-factor authentication
  • Continuous monitoring of systems and networks

Incident Response & Notification:

  • In the event of a cybersecurity incident or breach, we will promptly investigate, contain, and remediate
  • Clients will be notified in accordance with SEC, state, and federal regulatory requirements
  • Records of incidents and responses are maintained for audit and regulatory review
7

AI and Automated Decision-Making Disclosure

  • Eshel Bot uses AI and quantitative algorithms to manage discretionary client accounts
  • Client data may be used in model training, backtesting, or performance analysis
  • Use of client data for AI purposes is confidential, anonymized where feasible, and limited to improving investment decision quality
  • Automated decisions may result in trades executed without prior client review, consistent with the discretionary agreement
8

Data Retention

  • Client data is retained as long as the advisory relationship exists
  • Retention also complies with SEC recordkeeping requirements, including trade logs, audit trails, and regulatory submissions
  • Clients may request deletion of personal data, subject to legal and regulatory obligations
9

Cross-References

  • This Privacy Policy is integrated with Form ADV Part 2A (Firm Brochure)
  • All services, data usage, and disclosures are governed by the Client Advisory Agreement
  • In case of conflict, the Client Advisory Agreement governs trade execution and data consent
10

Contact Information

For questions regarding this Privacy Policy or your privacy rights:

Eshel Spring LLC

100 Summit Drive, Burlington, MA 01803

Email: info@eshelbot.com

Phone: (781) 518-8660

Website: www.eshelbot.com

Your privacy matters to us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please don't hesitate to contact us.

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