Privacy Policy

SUMMARY OF KEY POINTS

SECTION 1.

This summary is provided for convenience. It does not replace the full Policy that follows, and the full Policy controls.

We are a single family office. We do not offer services to the public, do not accept outside capital, and do not solicit clients through our website.

We never sell your information. We do not sell personal information, do not share it for cross context behavioral advertising, and do not disclose it for any third party’s independent marketing purposes.

Some of our activity is public by law. We engage in lobbying and public policy work. Federal, state, and municipal law compels public disclosure of certain lobbying and political contribution information. Once filed, that information is public and beyond our control. Section 7 explains this in detail.

We hold sensitive information. This includes financial, estate planning, and, for certain individuals, political contribution and affiliation records collected for compliance screening. We treat these categories with heightened care.

You have rights. We extend rights of access, correction, deletion, portability, and objection to every individual we hold information about, regardless of where you live, subject to the legal and fiduciary limits described at Section 15.

We are a United States business. We collect, store, and process information in the United States and do not target individuals outside it.

How to reach us. Contact details appear at Section 21.

INTRODUCTION AND SCOPE

SECTION 2.

DoublePlus, LLC, together with its subsidiaries, affiliated management companies, private trust companies, general partners, and special purpose vehicles, referred to in this Policy as the “Firm,” “we,” “us,” or “our,” respects the confidentiality of the individuals and entities with whom it works.

This Policy explains how we collect, use, disclose, retain, and safeguard Personal Information. “Personal Information” means information that identifies, relates to, describes, or could reasonably be linked with a particular individual or household. This Policy applies to:

2.1 The website located at www.doubleplus.org and any successor or affiliated site, referred to as the “Site”;

2.2 Our provision of investment management, treasury, accounting, tax coordination, philanthropic administration, concierge, trust administration, and related family office services;

2.3 Our government relations, public policy, lobbying, and political engagement activities, referred to collectively as “Government Affairs Activities”; and

2.4 Our interactions with prospective counterparties, vendors, service providers, grant applicants, personnel, and job applicants.

2.5 Applicable law. We are organized and operate in the United States. Our practices are designed to satisfy the privacy, data security, breach notification, and lobbying and campaign finance laws of the jurisdictions in which we are organized, maintain operations, or hold information. Where the law of your jurisdiction affords you greater protection than this Policy describes, that law governs.

2.6 Precedence. This Policy does not apply to information governed by a separate written agreement, engagement letter, trust instrument, or partnership agreement, which controls in the event of conflict.

OUR STRUCTURE AND FINANCIAL PRIVACY NOTICE

SECTION 3.

The Firm operates as a single family office and does not hold itself out to the public as an investment adviser. Where the Firm or any affiliate constitutes a “financial institution” within the meaning of the Gramm Leach Bliley Act, 15 U.S.C. § 6801 et seq., the privacy notice required by that statute and by the implementing regulations of the Federal Trade Commission at 16 C.F.R. Part 313 is delivered separately, at the outset of the relationship and thereafter as required, and is incorporated here by reference. In the event of any conflict between that notice and this Policy as to nonpublic personal financial information, that notice controls.

CATEGORIES OF INFORMATION WE COLLECT

SECTION 4.

4.1 Identifiers. Name, alias, postal address, electronic mail address, telephone number, date of birth, and government identification numbers such as Social Security number, taxpayer identification number, passport number, and driver licence number.

4.2 Family and relationship information. Marital status, dependents, beneficiaries, guardianship arrangements, and succession intentions.

4.3 Financial information. Account numbers, balances, holdings, transaction history, credit history, income, net worth, tax filings, and sources of wealth.

4.4 Professional information. Position, employer, board memberships, and business affiliations.

4.5 Estate planning information. Trust and testamentary documents, powers of attorney, and health care directives.

4.6 Philanthropic information. Grant history, charitable interests, and donee relationships.

4.7 Technical information. When you access the Site we may collect internet protocol address, device and browser type, operating system, referring and exit pages, pages viewed, access times, and similar log data, as described at Section 16.

4.8 Sensitive information. In the course of Government Affairs Activities and associated compliance screening, we may collect political party affiliation, political contribution history, political opinions expressed to us, philosophical beliefs, and membership in advocacy organisations. We may collect health information where necessary for benefits administration, travel arrangements, or fiduciary decision making, and biometric or geolocation data where required for physical security. We collect sensitive information only where a lawful basis exists, use it only for the purpose for which it was collected and any compatible purpose, and, where consent is required by applicable law, collect it only with consent. We do not sell sensitive information and do not use it to infer characteristics about you.

4.9 Correspondence. Communications you send to us and any other information you elect to supply.

SOURCES OF INFORMATION

SECTION 5.

We collect Personal Information directly from you, automatically through the Site, and from third parties. Third party sources include custodians, banks, brokers, fund administrators, accountants, attorneys, insurers, title companies, credit bureaus, sanctions and politically exposed person screening providers, public records, court filings, campaign finance databases, lobbying disclosure registries, and commercially available data sources.

HOW WE USE INFORMATION

SECTION 6.

We use Personal Information only for the purposes set out below and for purposes compatible with them. We do not use Personal Information for materially different purposes without first providing notice and, where required, obtaining consent.

6.1 To provide, administer, and improve family office services;

6.2 To execute, settle, and record investment and treasury transactions;

6.3 To prepare and file tax returns, information returns, and regulatory reports;

6.4 To administer trusts, estates, foundations, and charitable vehicles;

6.5 To conduct diligence, credit assessment, and counterparty evaluation;

6.6 To satisfy know your customer, anti money laundering, sanctions, and beneficial ownership obligations;

6.7 To plan, conduct, document, and report Government Affairs Activities, including preparation of registrations and periodic reports required by the Lobbying Disclosure Act, 2 U.S.C. § 1601 et seq., and by applicable state and municipal lobbying statutes and ordinances;

6.8 To screen proposed political contributions and related activity against applicable pay to play, contribution limit, corporate contribution, and conflict of interest rules before any contribution is made;

6.9 To maintain the security, integrity, and continuity of our systems and premises, and to detect and prevent fraud;

6.10 To establish, exercise, or defend legal claims and to respond to lawful process;

6.11 To communicate with you and respond to enquiries; and

6.12 To comply with any other legal or regulatory obligation.

GOVERNMENT AFFAIRS ACTIVITIES AND PUBLIC DISCLOSURE

SECTION 7.

Please read this Section carefully. It describes circumstances in which information about you may become a matter of public record.

7.1 Mandatory public filings. Federal, state, and municipal law requires public disclosure of certain lobbying and political activity. Depending on the jurisdiction and the activity, a filing may include the name of the registrant and the client, the identity of individual lobbyists, the specific issues and bills addressed, the agencies and chambers contacted, compensation and expenditure amounts, the names of covered officials contacted, and the identity, employer, occupation, and address of political contributors.

At the federal level, registrations and periodic activity reports are filed under the Lobbying Disclosure Act, 2 U.S.C. § 1601 et seq., and published by the Clerk of the House of Representatives and the Secretary of the Senate. Semiannual reports of certain political contributions and honorary expenditures are filed under 2 U.S.C. § 1604(d). Campaign finance reports are filed with and published by the Federal Election Commission under 52 U.S.C. § 30101 et seq. Comparable registration and reporting regimes apply at the state and municipal level in the jurisdictions where we are active, administered by state ethics commissions, campaign finance boards, and municipal clerks.

Once a filing is made, the information it contains is public and beyond our control. We cannot delete, redact, or recall it, and a request to exercise a deletion right under Section 15 will not remove it.

7.2 Contribution screening. Where you are a covered associate, employee, contractor, family member, or affiliate whose political activity may be attributed to the Firm, we may collect and retain records of your political contributions, solicitations, and volunteer activity, including activity undertaken in a personal capacity, in order to screen for compliance with applicable pay to play and attribution rules. We use these records solely as a compliance control. Access is restricted to personnel with a compliance need, and the records are retained only for the period required by the applicable rule and any associated limitation period.

7.3 Entity attribution. A contribution by a limited liability company may be attributed to its members according to its federal tax classification under 11 C.F.R. § 110.1(g) and comparable state provisions. Where attribution applies, the identity of the attributed member may appear in public campaign finance reports.

7.4 Foreign principals. Where any principal, client, or funding source is a foreign principal within the meaning of the Foreign Agents Registration Act, 22 U.S.C. § 611 et seq., additional registration and disclosure obligations may apply and additional information may become public.

7.5 Coalition and joint advocacy. Where we participate in coalitions, trade associations, or joint advocacy efforts, information about your participation may be shared with coalition members and may appear in coalition filings.

7.6 No political solicitation. Nothing in this Policy or on the Site constitutes a solicitation of political contributions. We do not solicit or direct contributions from Site visitors.

DISCLOSURE OF INFORMATION

SECTION 8.

We disclose Personal Information only as follows:

8.1 To affiliates and to personnel with a legitimate need to know;

8.2 To service providers and professional advisers, including custodians, banks, administrators, auditors, accountants, attorneys, insurers, technology vendors, and consultants. Each is engaged under a written contract that limits use of the information to the services performed for us, prohibits retention, use, or disclosure for any other purpose, requires safeguards at least as protective as those described at Section 12, and requires deletion or return on termination;

8.3 To government authorities, regulators, and self regulatory organisations, whether pursuant to mandatory filing obligations, subpoena, court order, examination, or other lawful process. Where we are permitted to do so, we will notify you before responding to compulsory process seeking your information;

8.4 As part of the public filings described at Section 7;

8.5 To counterparties and their advisers to the extent necessary to execute a transaction you have authorised;

8.6 In connection with a merger, reorganization, restructuring, or transfer of assets involving the Firm, subject to confidentiality protections and to the successor being bound by commitments no less protective than this Policy;

8.7 With your direction or consent; and

8.8 As otherwise permitted or required by law.

WE DO NOT SELL OR SHARE PERSONAL INFORMATION

SECTION 9.

We do not sell Personal Information and have not done so. We do not share Personal Information for cross context behavioral advertising. We do not disclose Personal Information for any third party’s independent marketing purposes. We do not sell or share the Personal Information of any individual we know to be under the age of eighteen. We do not offer financial incentives in exchange for Personal Information.

CONFIDENTIALITY OF TRUST AND FIDUCIARY INFORMATION

SECTION 10.

Information concerning trusts we administer is treated as confidential and is disclosed only as permitted by the governing instrument, by applicable trust law, and by any order restricting disclosure. Where a governing instrument limits or waives the duty to inform and report, we administer information access consistent with that instrument. Nothing in this Policy enlarges or diminishes any right to information that a beneficiary holds under the governing instrument or applicable law.

PERSONNEL, APPLICANTS, AND HOUSEHOLD STAFF

SECTION 11.

We collect Personal Information from personnel, contractors, household staff, and job applicants for recruitment, payroll, benefits, tax withholding, immigration compliance, background screening, physical and information security, and personnel administration. Applicant information is retained only for the period required by applicable recordkeeping rules and thereafter deleted unless the applicant asks to be considered for future roles.

Where an individual is subject to the contribution screening described at Section 7.2, that screening is conducted as a discrete compliance control. We do not use records of lawful personal political activity for any employment decision, and applicable law in several jurisdictions prohibits us from doing so.

DATA SECURITY

SECTION 12.

We maintain a written information security program with administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, alteration, and destruction, appropriate to our size, the nature of our activities, and the sensitivity of the information we hold. The program includes a designated individual accountable for information security, a documented risk assessment reviewed periodically, access controls on a least privilege basis, multifactor authentication, encryption of data at rest and in transit, network monitoring and logging, secure disposal, vendor diligence and contractual security commitments, a written incident response plan tested periodically, business continuity and backup arrangements, and personnel training at hire and at regular intervals thereafter.

The program is maintained so as to satisfy the reasonable safeguards required by applicable state data security law, and, where the Firm is subject to the Federal Trade Commission Standards for Safeguarding Customer Information at 16 C.F.R. Part 314, in accordance with that rule.

No system is impenetrable. We cannot guarantee absolute security, and transmissions to us over the internet are made at your own risk. Please do not transmit account numbers, government identification numbers, or other sensitive information through unencrypted electronic mail or the Site contact form.

NOTIFICATION OF SECURITY INCIDENTS

SECTION 13.

If we determine that a security incident has compromised Personal Information, we will notify affected individuals, and the regulators, consumer reporting agencies, and other recipients entitled to notice, as and when required by the applicable federal, state, and sectoral breach notification laws of each affected jurisdiction. Notice will be given in the most expedient time possible and without unreasonable delay, subject only to the legitimate needs of law enforcement and to the measures necessary to determine the scope of the incident and restore the integrity of our systems. Where we are not required to give notice but consider that an incident is material to you, we will use reasonable efforts to inform you in any event.

RETENTION

SECTION 14.

We retain each category of Personal Information for as long as necessary to fulfill the purposes described at Section 6, and thereafter for the period required by the applicable obligation. We determine the retention period by reference to the following criteria: the duration of our relationship with you; statutory and regulatory recordkeeping requirements, including lobbying disclosure, campaign finance, tax, employment, and fiduciary accounting obligations; the limitation period applicable to any claim that could arise; and any litigation hold or governmental preservation demand, which suspends deletion until lifted. When retention is no longer required we destroy or deidentify the information in a manner reasonably designed to prevent reconstruction.

YOUR RIGHTS AND CHOICES

SECTION 15.

15.1 Rights we extend to everyone. As a matter of policy, and regardless of where you live or whether a statute compels it, we extend to every individual whose Personal Information we hold the rights to: know what Personal Information we hold and how we use and disclose it; obtain a copy in a portable format; correct inaccurate information; request deletion; opt out of any sale, sharing, or targeted advertising, none of which we conduct; limit our use of sensitive information; object to processing; and appeal a decision declining a request.

15.2 How to make a request. Submit a request to the contact at Section 21. An authorized agent may submit a request on your behalf on production of written authorization, and we may ask you to confirm the authorization directly.

15.3 Verification. We will take reasonable steps to verify your identity before responding, using information already in our possession and proportionate to the sensitivity of the information requested. We will not use information supplied for verification for any other purpose.

15.4 Timing. We will acknowledge a request promptly and respond within forty five days. Where a request is complex or numerous, we may extend that period by a further forty five days and will tell you why within the initial period.

15.5 Limits. We will honour a request except to the extent that doing so would conflict with a legal, regulatory, fiduciary, or contractual obligation, would compromise the rights of another person, would prejudice the establishment or defence of a legal claim, or is otherwise excepted by applicable law. We cannot alter or withdraw information already contained in the public filings described at Section 7. Where we decline a request in whole or in part, we will tell you why and how to appeal.

15.6 Appeals. You may appeal a declined request by writing to the contact at Section 21 and marking the correspondence “Privacy Appeal.” We will respond in writing within forty five days, setting out our reasoning. If your appeal is denied you may complain to the attorney general or supervisory authority of your jurisdiction, and we will provide the relevant contact details on request.

15.7 No charge and no retaliation. We do not charge for responding to a request unless it is manifestly unfounded or excessive, in which case we will tell you the reason and the amount before proceeding. We will not deny you goods or services, or otherwise discriminate or retaliate against you, for exercising any right under this Section.

15.8 Communications. We do not conduct consumer marketing. Where we send periodic communications you may opt out at any time using the unsubscribe mechanism or by contacting us. We will continue to send you communications necessary to administer our relationship.

COOKIES, ANALYTICS, AND PREFERENCE SIGNALS

SECTION 16.

The Site uses strictly necessary cookies and may use first party analytics cookies to understand aggregate usage. We do not use the Site for behavioral advertising, cross site tracking, or audience segmentation. You may configure your browser to refuse cookies, though portions of the Site may not function properly as a result.

We honour the Global Privacy Control and comparable browser based opt out preference signals as an opt out of any sale or sharing of Personal Information, notwithstanding that we conduct neither. Because no common industry standard has been adopted for the browser Do Not Track signal, we do not respond to it separately; the preference signals described in this paragraph are the effective mechanism.

AUTOMATED DECISION MAKING AND PROFILING

SECTION 17.

We do not use automated processing, including profiling, to make decisions that produce legal or similarly significant effects concerning you without meaningful human review. Where any tool assists our personnel in a screening, diligence, or compliance task, a person remains responsible for the decision and you may ask for an explanation of the outcome and for the decision to be reconsidered.

CHILDREN

SECTION 18.

The Site is not directed to children and we do not knowingly collect Personal Information from children through the Site. If we learn that we have collected Personal Information from a child through the Site, we will delete it promptly. We may hold information about minor beneficiaries in the ordinary course of trust and estate administration, obtained from parents, guardians, or fiduciaries rather than from the minor, and we treat that information as sensitive.

ACCESSIBILITY OF THIS NOTICE

SECTION 19.

We aim to make this Policy accessible to individuals with disabilities and to present it in a format that can be printed and retained. If you need this Policy in an alternative format, contact us at Section 21 and we will provide one.

CHANGES TO THIS POLICY

SECTION 20.

We may amend this Policy. The revised Policy takes effect on posting to the Site with an updated Last Revised date and version number, except that a material change affecting nonpublic personal financial information will be communicated as required by applicable law before it takes effect. Where a change materially reduces your rights or expands our use of Personal Information, we will provide prominent advance notice and, where required, obtain your consent. We retain and will provide on request each prior published version of this Policy.

HOW TO CONTACT US

SECTION 21.

If you have any questions or concerns about this policy, email us at privacy@doubleplus.org. We will acknowledge correspondence sent to this address promptly.