Privacy Policy

EFFECTIVE 2025 · APPLIES TO MSRMARKE.SHOP

1. Scope of this policy

This policy covers information collected through msrmarke.shop (pages visited, form submissions, correspondence) and information received in the ordinary course of our desks' work: principal dealing, fee-based advisory and management, trust and custody administration, and market functions. It does not govern third-party sites we link to, and it supplements — never replaces — confidentiality duties under trust instruments, advisory agreements, escrow instructions and law.

2. Information we collect

2.1 Information you give us

• Contact details: name, company or capacity, email address and phone number sent through the ticket form or email.
• Correspondence content: whatever you write to us, including quote references and the matters you raise.
• Engagement information: where a signed engagement exists, information reasonably required to perform — identification details, suitability facts gathered under advisory agreements, fiduciary files and administrative records kept at the desk.

2.2 Information collected automatically

• Server logs: IP address, browser type, pages requested and timestamps, collected by our hosting provider for security and delivery.
• No tracking pixels: we do not run advertising pixels or cross-site trackers on this website.

2.3 Information we do not want

Do not send account numbers, wire or transfer instructions, credentials, signature pages, trust documents or order instructions through website forms or ordinary email. Operational instructions move only through channels agreed under a signed engagement.

3. How we use information

• Responding to tickets directed to the desk.
• Evaluating and documenting requested engagements.
• Performing signed engagements: advisory suitability, fund and trust administration, custody records, transfer and clearing files.
• Meeting legal, tax, fiduciary, AML and record-keeping obligations under Utah and federal law.
• Protecting the firm, its clients and correspondents from fraud and impersonation, and enforcing our terms.

4. Legal bases & consent

We process personal information to respond to inquiries you initiate, to perform contracts you are party to, to comply with legal duties (fiduciary records, tax, securities and trust law), and for legitimate interests in running a secure, professional desk. Where consent is the basis you may withdraw it by contacting us; withdrawal does not affect prior processing.

5. Disclosure of information

We do not sell personal information. We may share it with:

• Service providers hosting, email and records systems under confidentiality obligations;
• Counsel, accountants and counterparties — only as needed for the matter at hand;
• Regulators and courts where the law requires, including trust, securities and fiduciary supervision;
• Successors if the business is reorganized or sold, subject to the same confidentiality.

6. Confidentiality of fiduciary records

Trust instruments, estate files, custody records, escrow files and advisory notes are confidential fiduciary records. Access is limited to personnel who need it for the engagement. We do not discuss a client's positions, holdings or instructions with third parties without authorization or lawful compulsion.

7. Security

We maintain reasonable administrative, technical and physical safeguards: restricted access to fiduciary and engagement files, encryption in transit for hosted services, and independent verification before acting on any instruction that changes banking, beneficiaries or records. No system is perfectly secure; if we learn of a breach affecting your information we will notify you as the law requires.

8. Retention

• Website tickets: retained while the matter is active, then archived or deleted within 24 months unless an engagement follows.
• Engagement and fiduciary records: retained for the periods required by Utah law, governing instruments and our record-keeping schedule — typically at least seven years, longer where trust or securities rules require.
• Server logs: retained by the hosting provider under its own schedule.

9. Your rights

Depending on your jurisdiction you may request access to, correction of, or deletion of personal information we hold about you, and may object to certain processing. We will honor requests as the law permits — noting that fiduciary duties, signed agreements and legal-retention rules may limit deletion. Email reach.e.donnelly@msrmarke.shop with the subject "Privacy Request."

10. Children

Our desks serve adult and institutional correspondents. We do not knowingly collect personal information from children under 13. If you believe a child has submitted information, contact us and we will delete it.

11. Impersonation & payment-fraud warning

We will never email you unsolicited investment offers, unexpected wire or transfer instructions, requests for account credentials, or "guaranteed return" pitches. If you receive such a message claiming to be from KEM, verify by phone at +1 (661) 885-2290 before acting — using a number you already know, not one from the suspicious message.

12. Changes & contact

We may update this policy; the effective date above reflects the current version. Material changes will be posted on this page. Contact: KEM CAPITAL INVESTMENTS LLC, 449 W 430 S, Spanish Fork, UT 84660 · reach.e.donnelly@msrmarke.shop · +1 (661) 885-2290.