Privacy Policy

What this covers

Pragmatic Capital Management (“Pragmatic,” “we,” “us”) operates pragmaticcap.com and the related newsletter, video, and research publications. This policy explains what information we collect when you use the site or subscribe to our publications, how we use it, and the choices you have.

Information we collect

Information you provide. When you submit the contact form, request materials, or subscribe to a publication, we collect what you enter: typically your name, organization, and email address, and whether you have requested access to Institutional Insights.

Information collected automatically. When you visit the site, our hosting provider and analytics tools record standard technical data: IP address, browser and device type, pages viewed, the page that referred you, and timestamps. The contact form also records the referring page and any campaign parameters in the link you arrived from. We use cookies and similar technologies for this purpose, including tags from advertising platforms that let us measure whether an ad led to a visit or a submission.

Information from third parties. If you reach us through a platform such as LinkedIn or Substack, that platform may share with us information you have made available there, subject to its own privacy terms.

How we use information

• To send the materials and publications you request.
• To respond to your inquiry.
• To operate, secure, and improve the site.
• To understand which content and advertising brings people to the site, and to show our advertising to people likely to find it relevant.
• To meet legal and regulatory obligations that apply to an investment adviser.

We do not sell your personal information.

Who we share information with

We share information only with service providers that help us run the site and publications, and only as needed for them to do so:

• Hosting and forms: Netlify, which serves the site, keeps server logs, and stores contact-form submissions.
• Publishing and email: Substack, which delivers our newsletter and manages subscriptions.
• Video: YouTube, where our videos are hosted. Viewing them is subject to Google’s privacy policy.
• Advertising and analytics: LinkedIn, Google and similar platforms whose tags we use to measure visits and conversions from our advertising, and to show our advertising to people who have visited this site. These platforms may associate your visit with your account on their service under their own policies.

We may also disclose information when required by law, regulation, or a request from a regulator with authority over us, or to protect the rights, safety, or property of Pragmatic or others.

Cookies and tracking

You can block or delete cookies through your browser settings; doing so may limit some site functions. Advertising platforms offer their own opt-outs. LinkedIn’s is in your LinkedIn account settings under advertising data. Google’s is at adssettings.google.com.

Your choices and rights

You can unsubscribe from any publication using the link in each email. You can ask us to access, correct, or delete the personal information we hold about you, or to stop using it for a particular purpose, through the contact page. We will respond within the time required by applicable law.

California residents. California law gives you the right to know what personal information we collect and how we use and share it, to request deletion, to correct inaccurate information, and not to be discriminated against for exercising these rights. We do not sell or share personal information for cross-context behavioral advertising as those terms are defined under California law. You may designate an authorized agent to make a request on your behalf; we may ask for verification.

Visitors outside the United States. The site is operated from the United States and information is processed here. If you are in a jurisdiction with additional data-protection rights, such as the European Economic Area or the United Kingdom, you may have the right to access, correct, delete, port, or restrict processing of your information, and to object to processing based on our legitimate interests. Use the contact page to exercise those rights.

Retention

We keep contact and subscriber information for as long as you remain subscribed or in contact with us, and afterwards as needed to meet recordkeeping obligations that apply to investment advisers. Server logs and analytics data are retained for the periods set by our providers.

Security

We use reasonable administrative and technical measures to protect information, including access controls and reputable third-party providers. No method of transmission or storage is completely secure.

Children

The site and publications are intended for adults. We do not knowingly collect personal information from anyone under 18.

Not an offer

Nothing on the site or in our publications is an offer to sell or a solicitation of an offer to buy any security, or investment advice to any person. Any offering of interests in a fund managed by Pragmatic is made only to qualified investors through definitive offering documents.

Changes

We may update this policy from time to time. The effective date above shows when it was last revised.