Effective Date: June 28, 2026
Antonio, CFA (“we,” “our,” or “us”) is deeply committed to maintaining the absolute confidentiality, integrity, and security of the non-public personal and financial information entrusted to us by our current, prospective, and former clients.
This Privacy Policy explains how we collect, utilize, safeguard, and restrict the sharing of your personal data across our wealth management, advisory, and brokerage operations, in strict compliance with the Gramm-Leach-Bliley Act (GLBA), SEC Regulation S-P, and applicable New York state privacy regulations.
1. Information We Collect
In order to provide bespoke wealth strategies, institutional-grade portfolio management, and seamless capital market executions, we must collect specific personal and financial data. This information includes:
- Identifiers & Contact Details: Your full name, residential address, telephone number, email address, Social Security Number (SSN), taxpayer identification number, and passport/driver’s license details (collected for mandatory Know Your Customer (KYC) and Anti-Money Laundering (AML) regulatory compliance).
- Financial Profile Data: Net worth, liquid assets, annual income, source of wealth, investment objectives, risk tolerances, employment details, corporate executive compensation packages (RSUs, ISOs, deferred compensation), and tax brackets.
- Account & Transaction History: Investment balances, custodian account numbers, trading histories, margin agreements, and wire transfer instructions executed through our affiliate broker-dealer network.
- Digital Interaction Data: IP addresses, cookies, and website usage analytics collected automatically when you browse our secure digital portals.
2. How We Use Your Information
We utilize your personal and financial information exclusively to conduct our core advisory and brokerage operations, including:
- Designing and implementing customized portfolio allocations, asset location strategies, and holistic financial plans.
- Opening and maintaining your accounts with qualified third-party clearing firms and custodians.
- Executing securities trades, private credit placements, or alternative investment transactions on your behalf.
- Complying with federal and state regulatory mandates, including identity verification, fraud prevention, and audit reporting.
3. How and When We Share Information
We do not sell, rent, trade, or market your personal information to any third party under any circumstances.
To deliver comprehensive wealth services, we share your data only with specific, vetted entities as permitted or required by law:
- Service Providers & Custodians: We share data with financial institutions, clearinghouses, and qualified custodians (e.g., Charles Schwab, Fidelity, or our executing broker-dealer) solely to service and clear transactions for your account.
- Your Designated Professionals: At your explicit written direction, we coordinate and share data with your external legal counsel, CPA, corporate general counsel, or family office trustees to align your estate and tax planning.
- Regulatory & Legal Authorities: We disclose information when required by law to comply with valid subpoenas, court orders, or requests from regulatory oversight bodies including the SEC, FINRA, or state banking authorities.
4. Information Security & Data Safeguards
We implement strict physical, electronic, and procedural safeguards designed to protect your non-public personal information from unauthorized access, alteration, or destruction.
- Encryption & Security Infrastructure: All electronic communication, client portals, and cloud data architecture utilize enterprise-grade, multi-layer encryption.
- Access Control: Access to your data is strictly limited to Antonio and authorized support personnel who require that specific information to manage your relationship or execute transactions.
- Vendor Due Diligence: We subject all third-party financial technology tools, custodians, and software partners to rigorous institutional cybersecurity underwriting before integrating them into our workflow.
5. Opt-Out Rights & State-Specific Disclosures
Federal and state laws give you the right to limit some sharing of your information. Because our business model operates entirely on a private, non-marketing basis, we do not share your information with non-affiliates for marketing or joint-promotional purposes.
New York Privacy Rights
For our clients residing in New York State and New York City, we actively manage data processing in alignment with emerging state-level data privacy acts. You have the right to request access to the specific pieces of personal information we have collected, verify its accuracy, or request deletion (subject to regulatory record-keeping laws enforced by the SEC and FINRA, which require financial records to be permanently maintained for specific multi-year durations).
6. Modifications to Our Privacy Notice
We reserve the right to amend this Privacy Policy at any time to reflect updates in cybersecurity tech, regulatory evolution, or changes in our operational structure. If any material changes are made regarding how we handle your non-public personal information, we will provide you with a revised notice directly via email or our secure client communication platform before the changes take effect.
Contact & Inquiries
If you have any questions, concerns, or require further clarification regarding our data privacy protocols and cybersecurity infrastructure, please contact us directly at:
Antonio S Amato, CFA
Attn: Privacy & Compliance Operations
Email: compliance@antoniofeedlink.com