Privacy Notice

Last Revised: April 12, 2024


Privacy Notice
Alta Summit Capital, LLC d/b/a AgentSmyth Advisors or AgentSmyth, LLC (hereinafter the “Company”, “I”, “we” or “us”) respects your privacy, and we have created this data privacy notice to inform you about how we collect, use, disclose and otherwise process personal data that you and others provide to us in compliance with applicable privacy laws, including, but not limited to, the California Consumer Privacy Act (CCPA), California Privacy Rights Act 2020 (CPRA), and the EU General Data Protection Regulation (GDPR).

AgentSmyth delivers a range of AI-driven research and analytics products and services through our website ( to help our customers make informed investment decisions. These products and services include, but are not limited to, access to autonomous AI agents that integrate into financial workflows to provide research, analytics and insights (together the "Services"). This Notice: (a) describes the types of information we may collect from you or that you may provide to us when you visit our website or otherwise use the Services, and (b) describes our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Notice supplements any other privacy related notices and policies we may provide to you, and is not intended to override them. If you do not agree with this Privacy Notice in general or any part of it, please do not use our Services or provide your personal data to us. We may make changes to this Notice from time to time and will update the last revised date, post the updated version on our website and take any other steps necessary to comply with applicable law. Your continued use of the website is deemed to be acceptance of those changes, so please check this Notice periodically for updates.

The Services may include links to other third party websites. This Privacy Notice applies only to our website and not to third-party websites accessible from the website, each of which may have privacy policies materially different from this Privacy Notice. If you visit other third-party websites, we are not responsible for the privacy practices or content of those sites.

We are the Data Controller, unless stated otherwise, of personal data relating to various classes of Data Subjects, in this instance, "you", "your".

Type of Data we Collect and Process
The categories of personal data we collect depend on how you interact with us and our Services. We collect personal data that you provide to us directly, personal data we collect through automatic data collection activities, and personal data from other sources, such as third-party services and organizations.

We only collect and process necessary personal data. The types of personal data we may collect, includes, but is not limited to:

Identity Data (first name, surname, username)
Login Credentials (username & password)
Contact Data (email address, company address)
Billing & Payment Data (payment card details, billing address)
Device Data (IP address, device type, operating system)
Service Usage Data (automatic data collection of your interactions and usage of our website and services)

There are circumstances where we may process personal data, including personal data about and on behalf of our Services and customers. This Privacy Notice does not apply when we act as a Data Processor handling personal data on the instruction of Data Controllers.

How we collect your data
Personal Data we collect Directly from You
You may provide us with your personal data such as contact information, including first name, last name, email address, and billing information.

Personal Data we collect from other Sources
We may collect personal data about you from other sources including:

Third parties and publicly available sources that you chose to share your data with, e.g. if you interact with us on social media, we will collect the messages contents, your social media handle and other personal data related to the interaction.
When you visit our website, and accept our cookies, third parties may automatically collect personal data sent to us by your computer, mobile phone, or other device.
Any personal data that we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible or liable for the accuracy of the personal data provided to us by third parties and are not responsible for their policies or practices.

Lawful Bases for Processing
Any processing of personal data is only lawful where it has a "legal basis." Article 6 of the GDPR sets out what these potential legal bases are, namely: consent, performance of a contract, legal obligation, vital interests, public task, and legitimate interests.

For all Data Subjects, we have legal obligations to disclose and share personal data in the following circumstances:

Cooperate with law enforcement, judicial orders, and regulatory inquiries; and
Protect the interests, and ensure the safety and security, of us, our users, a third party, or the public;
The legal bases on which we are processing your personal data are listed below:

We approach existing and prospective customers to create awareness and make sales to interested parties. As a prospective customer, the legal basis for processing your personal data is legitimate interest, and for the performance of a contract once you are an existing customer.
Should we become aware of any reason to cease processing your personal data, and that reason overrides our legitimate interests, then we will not process it unless we have received your consent or are otherwise required to or permitted by law.

Security and Storage of Personal Data

Data security
We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. We leverage industry-standard cloud computing services and has implemented security best practices to protect your data. Unfortunately, no system nor the transmission of personal data via the internet is 100% secure. Although we take measures to protect your personal data, we cannot guarantee the security of your personal data that you provide to us. Any transmission of personal data is at your own risk. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

Where we Store and Process Personal Data
The personal data and other information that we collect from you may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection laws of the United States may not be equivalent or as comprehensive as the data protection laws as those in your country. Consequently, your personal data may be processed outside your jurisdiction, including in countries and jurisdictions that are not subject to an adequacy decision by the European Commission that may not provide for the same level of data protection as your jurisdiction.

To ensure appropriate level of protection for your personal data, we will govern cross-border transfers by a Data Processing Agreement (DPA), and adopt Standard Contractual Clauses (SCCs) where necessary, and make sure that a Transfer Impact Assessment (TIA) is carried out, if required.

Recipients of your Personal Data
We may disclose personal data that we collect, or you provide to us, as described in this Privacy Notice to the following groups:

Service Providers:
We use third party service providers to support our provision of Services to customers. For those service providers we may share your personal data with, where necessary, we have signed a Data Protection Agreement (DPA) to ensure that each service provider has the necessary measures in place to protect your data.

Disclosing Data for Other Reasons:
In certain circumstances, Data Protection laws allow personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Business Transactions:
In accordance with applicable legal obligations, your information may be provided to third parties in connection with a merger or acquisition, or as part of a corporate reorganization or stock sale or other change in corporate control or fundamental business change, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

Third Party Data Processors
As mentioned in this notice, we use third party data processors. You may request a list of all third party data processors used by us by sending an email request to

Retention Period
Once collected, your personal data is retained for as long as needed to provide the Services, as permitted by applicable law, and as necessary to comply with our legal obligations, resolve disputes or enforce our agreements. We may also anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes. In this case, we may use this personal data indefinitely without further notice to you however you will not be identifiable in this instance.

Use of Cookies
We use cookies for authentication and security, preferences and features, and to conduct analytics and research. Some cookies are automatically placed on your browser by our web server when you visit our website as they are needed before key features can be used. Cookies can be read, updated or deleted by the same servers each time you visit our website. We do not use third-party targeting cookies at present. However, should we do so in future, we will request your prior consent and you may opt-out or delete these cookies at any time.

We also use web beacons that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics.

Your Data Protection Rights

If you are an EU resident, under European data protection laws you have rights including:

Right of access - You have the right to request access to copies of your personal information.
Right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Right to withdraw consent – You have the right to withdraw previously given consent at any time. This may affect our ability to interact further with you.
Right to erasure - You have the right to ask us to erase your personal information. This is also known as the right to be forgotten.
Right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
Right to data portability - You have the right to ask that we transfer the personal information you gave us to another organization, or to you, in certain circumstances.
Right to not be subject to automated-decisions - Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. We do not currently carry out automated decision-making in connection with our relationship with you.
Right to object to marketing - You can object to our marketing communications at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you. You may also opt out by emailing Please note that regardless of your request, we may still use and share certain information as permitted by this notice or required by applicable law. You may not opt out of certain transactional emails such as those confirming your requests or updates regarding our privacy notice or other terms.

If you are a resident of California, under CCPA & CPRA you have rights including:

Right to rectification – Under CCPA/CPRA , you have the right to review and request changes to any of your 'personally identifiable information' which we process pursuant to CCPA/CPRA.
Right to Know - You have a right to request the following information about our collection, use and disclosure of your personal information over the prior 12 months, and ask that we provide you with a copy of the following:
Categories of and specific pieces of personal information we have collected about you;
Categories of sources from which we collect personal information;
The business or commercial purposes for collecting personal information;
Categories of third parties to whom the personal information was disclosed for a business purpose; and
Categories of personal information disclosed about you for a business purpose.

Right to Delete - Under the CCPA, you have a right to request that we delete personal information, subject to certain exceptions.
Right to opt-out / "say no" - Under CCPA you have the right to opt-out or "say no" to having your personal data sold to third parties.
Right to not be discriminated against for exercising any of the above rights.

If you are a resident of Nevada, under Nevada Law SB220 you have the following:

Right to opt-out. Under Nevada Law SB220 you have the right to opt out or "say no'' to having your personal data sold to third parties.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

If you are a resident of a non-EU country and would like further information in relation to your legal rights under applicable law or would like to exercise them, you may contact us at the contact listed below. We will consider all requests and provide our response within the time period stated by applicable law and as otherwise required by applicable law.

Regardless of your residency, you can object to our marketing communications at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you. You may also opt out by emailing Please note that regardless of your request, we may still use and share certain information as permitted by this notice or required by applicable law. You may not opt out of certain transactional emails such as those confirming your requests or updates regarding our privacy notice or other terms.