Privacy Policy

Last Updated: SEPTEMBER 23, 2026

This Capital Advisors Group Privacy Policy (this “Privacy Policy”) applies to the Capital Advisors Group, Inc. (together with its divisions and affiliates, “the Company,” “we,” “our,” and “us”) website located at https://www.lenterisadvisors.com/ and related URLs (the “Website”), and all websites, applications, platforms, products, software, tools, data, products, and services that are owned, created, developed, operated, or maintained by the Company and made available by us via the Website or that otherwise link to this Privacy Policy, including, but not limited to, the CounterpartyIQ® platform (collectively, the “Services”). The Website and the Services are referred to together in this Privacy Policy as the “Platform.”

This Privacy Policy explains: (i) what information we collect and how we process the information provided to us through the Platform; and (ii) options you have with respect to our use of your information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE PROCESS INFORMATION COLLECTED THROUGH THE PLATFORM. BY ACCESSING OR USING THE PLATFORM, YOU AGREE TO OUR USE OF YOUR INFORMATION AS DESCRIBED HEREIN. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE THE PLATFORM.

1. Collection of Information

Information We May Collect Directly From You. If you choose to use the Platform, including, without limitation, by creating an account, contacting us or otherwise interacting with the Platform, we may collect information from you. In order to receive or obtain access to our Platform, products or services, you may be required to provide us with certain information, including, for example, your name, email address, and information about your organization. Failure to provide such data may make it impossible for us to provide you with our Platform, products or services. The types of personal information collected and shared depend on the products or services provided to you. Information collected by us and our partners and suppliers may include, but is not necessarily limited to:

contact information, such as your name, email address, phone number, and mailing address;
log-in information, such as the username and password you use to access the Platform or any of our products or services or to create an account, and the associated data;
information we receive in the course of establishing a customer relationship or that you otherwise provide to us while engaging with the Platform, including, but not limited to, information and data provided in applications, forms, questionnaires, and through our Platform; and
user-generated content and messages, such as messages you send us when requesting customer support.

Information We May Collect From Your Computer or Device. We and our partners and suppliers may collect information about you automatically as you access the Platform, including, but not limited to, the following:

analytics data and logs used to monitor traffic and fix bugs, such as Google Analytics for traffic analysis and event metrics, internal logs, and the collection of obfuscated error tracking data. For example, we may collect information on web requests, the data sent in response to such requests, and the Internet Protocol (“IP”) addresses, the browser types, the browser languages, and timestamps for such requests;
data related to access and security of customer accounts, including information required for authentication logic such as login status, IP address, request timestamps, and success/failure rates;
analytics monitoring your actions taken while interacting with the Platform, such as the use of features and modifications to data; and
cookies used to store session information. The Company may use cookies to track usage of the Platform and to address security issues. We may also use cookies to store your preferences relating to use of our Platform. If you do not want to allow our Platform to place a cookie on your computer, you can change your browser’s settings to deny third-party cookies; however, denying third-party cookies may prevent you from using the Platform.

Information We May Collect About You From Third Parties. We may receive information about you from other sources, including third parties that help us update, expand, and analyze our records or prevent or detect fraud.

2. How We Use Your Information

The Company may use your information for various purposes to the extent permitted by applicable law, including, but not limited to, the following (collectively, “Our Purposes”):

to provide you with our Platform and products and services, including to identify you when you sign into your account, to respond to your inquiries, to communicate with you about the Platform, and for billing and collection purposes;
for planning and strategy development and other business purposes related to our Platform and products and services, including to enhance and improve our Platform and to analyze use of the Platform;
to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
to send you marketing e-mails about new proposals, opportunities, upcoming events, and other news, including, without limitation, information about products and services offered by us. You may opt out of receiving such information at any time. Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you; and
for any other related legitimate business purposes and as otherwise described herein.

3. How We Disclose Information

We may disclose your information in the following ways:

to our affiliates and subsidiaries for Our Purposes in connection with the management or servicing of your accounts or otherwise providing you with our Platform, products, or services, and as permitted or required by law;
to institutions with which we have joint business arrangements for Our Purposes in connection with the management or servicing of your account;
to persons we reasonably believe to be your authorized agents or representatives or regulators in order to satisfy the Company’s regulatory obligations and as otherwise required or permitted by law;
to vendors, service providers, and agents that we engage to help us provide the Platform or our other products and services and administer our business, provided that such entities are contractually obligated to maintain the confidentiality of that information;
when required by law, court order, or other government or law enforcement authority or regulatory agency;
when it may be necessary for Our Purposes as reasonably determined by us and in accordance with applicable law, including, without limitation, our interests in conducting our business, fulfilling contractual obligations, and managing and delivering the Platform and products and services; and
for other reasons when you provide us with consent to do so.

If we, or all or a portion of our assets, are acquired, or if we go out of business or enter bankruptcy, information would be one of the assets that may be transferred to or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of us or any of our assets may continue to use your information as set forth in this Privacy Policy.

4. Aggregated Data

We may aggregate and/or de-identify any information collected through our Platform so that such information can no longer be linked to you or your device (“Aggregated Data”). We may use such Aggregated Data for any lawful purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, partners, and sponsors.

5. Your Rights

You have the right to opt out of the sharing of your information to non-affiliated third parties and may do so via your designated support channel or by email at privacy@capitaladvisors.com. Please note that this may affect your experience with certain features of our Platform or products or services.

Depending on your jurisdiction of residence, you may have certain other rights with respect to your information as described in this section. If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us at privacy@capitaladvisors.com.

Your local laws may permit you to request that we: (a) provide access to and/or a copy of certain information we hold about you; (b) update information that is out of date or incorrect; or (c) delete certain information which we are holding about you. We will consider all requests and provide our response within the period stated by applicable law and as otherwise required by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate business interests or to comply with a legal obligation. We may request you (or an authorized agent filing a request on your behalf) provide us with information necessary to confirm your identity before responding to your request. Depending on applicable law, you may have the right to appeal our decision to deny your request. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.

6. Confidentiality and Security

We follow generally accepted industry standards to help protect your information. We directly or via our partners maintain physical, procedural, legal and electronic safeguards in an effort to protect your information from access by unauthorized parties. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at privacy@capitaladvisors.com.

7. Children

Minors should not use the Platform. By using the Platform or otherwise providing us with information, you represent that you have the legal capacity to enter into a binding agreement.

8. California Shine the Light Disclosure

If you are a California resident, you have the right to request one Notice of Information-Sharing Disclosure per year which will identify the third parties, if any, with whom we or any of our affiliates has shared the personal information we have collected from you. You may request the Notice of Information-Sharing Disclosure by contacting us using the contact information below, and we will respond to your request within 60 days. For accounts with a California mailing address, we will not share your information with a financial company for joint marketing purposes except as required or permitted by law

9. International Visitors

Because the Platform is operated from the United States, please note that your information may be transferred, processed, and stored in the United States. Whenever your information is transferred, processed, or stored by us, we take reasonable steps to protect your information in accordance with this Privacy Policy and applicable laws. By providing us with your information, you acknowledge any such transfer, processing, or storage.

10. Third-Party Practices

This Privacy Policy does not address the privacy practices of any third parties. Our Platform may contain links to third-party websites, products, or services. If you choose to use these links and associated features, please note that we are not responsible for their content or privacy practices, and that the use of such links and features may result in information such as your IP address and information collected through cookies being shared with the third parties that control these links and features. The collection, use, and disclosure of your information will be subject to the privacy policies of such third parties, and not this Privacy Policy. We urge you to read the privacy policies of these third parties if you choose to interact with these links and features.

11. Updates to This 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, but not limited to, the Platform. We will post changes to our Privacy Policy on the Website and encourage you to review our Privacy Policy when you use the Platform to stay informed. We will not, however, permit the sharing of your information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. If you disagree with the changes to this Privacy Policy, you should discontinue your use of the Platform.

At all times, you may request our current Privacy Policy by contacting the Company at (617) 630-8100 or by email at privacy@capitaladvisors.com.