PRIVACY POLICY
Last updated Nov 09, 2025
This Privacy Policy describes how eSmeb Inc. and its affiliate WaterfallWealth LLC (“we,” “our,” or “us”) collect, use, and protect information about clients and visitors to our website WaterfallWealth.ai. We are committed to protecting your privacy and the confidentiality of your personal information in accordance with Regulation S-P under the Investment Advisers Act of 1940.
Information We Collect
We collect nonpublic personal information (“Personal Information”) about you from:
Information you provide when you open an account or communicate with us (such as name, address, email, phone number, Social Security number, assets, and income).
Transactions and account activity through our platform and with your custodian or broker (such as Alpaca Securities LLC or Interactive Brokers LLC).
Website and platform usage information (such as log data, cookies, and analytics).
How We Use Information
We use Personal Information to:
Provide investment advisory and account services.
Open and maintain client accounts and process transactions.
Communicate with you about your account, products, or updates.
Comply with legal and regulatory obligations.
Improve our technology and user experience
Sharing of Information
We do not sell your Personal Information.
We may share information only as permitted by law, including with:
Service providers who help us operate our advisory business (such as custodians, broker-dealers, data storage providers, and compliance vendors).
Our affiliates that assist in providing technology or marketing services (such as WaterfallWealth LLC and FTToken Inc.).
Regulators, auditors, or law enforcement when legally required.
All service providers and affiliates that receive information are required to protect its confidentiality and use it only for the purposes for which it was provided.
Security of Your Information
We maintain physical, electronic, and procedural safeguards designed to protect your Personal Information in accordance with federal standards.
Access to your information is restricted to personnel and service providers who need it to perform their duties.
Although we use reasonable measures to protect your data, no method of electronic storage or transmission is entirely secure.
Your Choices
You may opt out of marketing communications at any time using the unsubscribe link.
You may request access to, correction of, or deletion of your Personal Information by contacting us at support@esmeb.com.
Changes to This Policy
We may update this Privacy Policy periodically. The most current version will always be posted on our website with the effective date shown above.
Contact Us
For questions about this Privacy Policy or our privacy practices, please contact us at support@esmeb.com.