WELARA WEBSITE PRIVACY POLICY
November 20, 2025
Introduction
This Privacy Policy describes how Welara Holdings, LLC ("Welara," "we," "our," or "us") and our affiliates collect, use, maintain, protect, and disclose information when you visit our website at https://www.welara.com (the "Site"). Welara's business structure includes SEC-registered investment adviser Welara Asset Management, LLC, and Welara Management, LLC, which provides ancillary services separate from investment advisory services.
This Privacy Policy applies to all visitors and users of our Site. Please note: If you are a client of Welara Asset Management, LLC receiving investment advisory services, you will receive a separate Privacy Notice as required by federal law that governs how we handle your personal financial information in connection with those advisory services.
By using our Site, you acknowledge the practices we outline in this Privacy Policy. If you do not agree with any part of this Privacy Policy, then please do not use our Site.
Updates to this Privacy Policy
We may update this Privacy Policy based upon evolving laws, regulations and industry standards, or as we may make changes to our business including our Site. We will post changes to our Privacy Policy on this page and encourage you to review our Privacy Policy when you use our Site to stay informed. Changes to this Privacy Policy will be effective immediately upon posting, unless we indicate otherwise, but will not apply retroactively. If we make changes that materially alter your privacy rights, we will take appropriate measures to inform you, consistent with the significance of the changes we make. By using the Site after we have posted changes to this Privacy Policy, you are agreeing to be bound by the updated Privacy Policy. If you disagree with the changes to this Privacy Policy, you should discontinue your use of the Site.
Children
The Site is not directed to, and we do not knowingly collect personal information from, anyone under the age of 18. If a parent or guardian becomes aware that their child has provided us with information, they should contact us. We will delete such information from our files as soon as reasonably practicable.
Personal Information We Collect
When you use our Site, you may provide us with personal information including your name, email address, phone number, and mailing address. This may occur when you:
- Contact us through our website
- Access our client portal
- Request information about our services
- Subscribe to updates or communications
- Device and browser information (browser type, operating system, device identifiers)
- Usage data (pages viewed, time spent on pages, referring websites, search terms)
- Network information (IP address, general location, internet service provider)
How We Use Personal Information
- To provide, operate and improve the Site;
- To answer your inquiries;
- To provide support and maintenance;
- To respond to your requests and feedback;
- To communicate with you about our services;
- To protect against fraud, unauthorized transactions, and other security risks;
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- To comply with legal obligations; and
- With your consent.
Privacy Technology Practices
Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals.
Links to Third-Party Sites
The Site may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Data Security
The security of your personal information is important to us. We employ a number of administrative, technical, and physical safeguards designed to protect the personal information we collect. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our Site. Any transmission of personal information is at your own risk.
In the event of a data security incident involving your personal information, we will take appropriate steps to investigate and respond to the incident in accordance with applicable law. Depending on the nature and scope of the incident, we may provide notice to affected individuals as required by applicable privacy and data protection laws.
Additional Disclosure for California Residents
Your Right to Know and Delete
You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and validate your request, we will include a list of your personal data that may have been disclosed and the categories of third parties the information may have been disclosed to.
You may request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request. We may deny your deletion request if retaining the information is proper and necessary or if an exception allowing us to retain the information applies under applicable law.
If your request is approved, we will delete or deidentify the relevant information and will direct our service providers to take similar action.
Exercising Your Rights to Know, Delete or Correct
To exercise your rights to know or delete described above, please submit a request by emailing us at privacy@welara.com.
Only you, or your authorized representative may make a request to know or delete related to your personal data. We may ask for your name, email address and account information to verify your identity or your authorized representative’s identity.
You may only submit a request to know twice within a 12-month period. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt, unless we require an extension. If we reasonably require an extension, we will inform you of the reason and extension period.
Non-Discrimination
We will not discriminate against you for exercising any of your data rights.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
California’s Shine the Light Law
California Civil Code Section 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of the information you provide through the website to third parties for their direct marketing purposes. To make such a request, please contact us at the information provided above.
Summary of Data Disclosed to Third Parties
In the preceding twelve (12) months, we may have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below. We do not “sell” or “share” your information as those terms are defined in the CCPA.
