Effective Date: September 23, 2025
This Privacy Policy (“Policy”) governs the collection, use, disclosure, retention, and protection of personal information by The Top Minds Strategists, HWH Inc., and related parties (collectively, “Company,” “we,” “us,” or “our”). This Policy applies to all users (“you,” “your”) who access or use our websites, platforms, or services.
1. Information We Collect
We collect personal information necessary to deliver and improve our financial strategy, insurance, and related services. This may include:
Personal identifiers: name, address, phone number, email address
Financial data: income, insurance details, investment preferences (only when voluntarily provided in connection with our services)
Digital identifiers: IP address, device information, cookies, and tracking data
Communications data: correspondence, preferences, and consent records
Sensitive data: where permitted by law, such as limited health data in connection with insurance products (we do not collect biometric data unless expressly disclosed and consented to)
We collect this data:
Directly from you,
Automatically through your interactions with our platforms, and
From third-party sources where legally permitted.
Children’s Privacy
Our services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. We comply with the Children’s Online Privacy Protection Act (COPPA) and do not knowingly collect information from anyone under 13. If such information is inadvertently collected, we will promptly delete it.
2. Use of Your Information
Your personal data is used strictly for:
Providing, maintaining, and improving our services and products
Responding to your inquiries and fulfilling your requests
Sending you educational, informational, or marketing communications (with your explicit consent)
Complying with regulatory, legal, or contractual obligations
Preventing fraud, unauthorized access, or other illegal activity
Conducting analytics, research, and service optimization
Automated Processing
We do not use automated decision-making or profiling that produces legal or significant effects, unless required by law or with your explicit consent.
Marketing Communications & Consent
By providing your phone number, email, or other contact details, you expressly consent to receive communications from us and our related parties, including calls, SMS/text messages, emails, and prerecorded messages, consistent with applicable law (including TCPA and CAN-SPAM).
Consent is not a condition of purchase.
Message and data rates may apply. Message frequency may vary.
We do not use your personal information for cross-context behavioral advertising or targeted advertising without your explicit opt-in consent.
3. Data Sharing and Disclosure
We do not sell your personal information.
Sharing occurs only:
With trusted affiliates, service providers, vendors, or licensed carriers essential to service delivery
When required by law, litigation, subpoena, or regulatory process
In the event of a corporate transaction (merger, sale, or asset transfer) with safeguards to protect your data
Based on your explicit, revocable consent
We do not share personal information with unaffiliated third parties for their own marketing purposes.
All third parties who receive your data must maintain the same level of protection we require, including confidentiality agreements and strict security protocols.
4. Data Retention and Deletion
We retain your personal data only as long as is necessary to comply with business, legal, tax, insurance, and regulatory requirements.
Retention periods vary by data category and are defined by applicable law.
We maintain a data retention schedule and review it periodically to ensure compliance.
Data no longer needed or requested to be deleted will be securely destroyed or anonymized.
5. Your Rights and Choices
Depending on your jurisdiction, you may have the following rights:
Accessing a copy of your personal information
Requesting correction or deletion of inaccurate or unnecessary data
Opting out of marketing communications at any time without affecting service delivery
Withdrawing your consent when given
Requesting restriction of processing or data portability (where applicable)
Lodging complaints with relevant data protection authorities
California Privacy Rights (CCPA/CPRA)
Right to know what personal information we collect and how it is used
Right to request deletion of your personal information (subject to legal exceptions)
Right to correct inaccurate information
Right to opt out of the sale or sharing of personal information (we do not sell or share, but we honor your rights)
Right to non-discrimination for exercising your rights
You can exercise your rights by contacting us (see Section 10).
6. Security of Your Information
We implement and continuously update administrative, technical, and physical safeguards, including encryption, access controls, audits, and employee training.
Access to personal data is limited to authorized employees, contractors, and agents who are bound by strict confidentiality obligations.
While no system can guarantee absolute security, we maintain comprehensive cybersecurity measures to minimize risk.
If a data breach poses risks to your rights or freedoms, we will notify you and applicable authorities promptly in accordance with law.
7. Cookies and Tracking Technologies
Our websites use cookies and similar technologies for functionality, analytics, personalization, and marketing.
Users may manage cookie preferences or opt out as outlined in our Cookie Policy.
Certain cookies may be considered “sharing” under CPRA. We honor opt-out requests where applicable.
We comply with applicable cookie regulations, including the EU ePrivacy Directive/GDPR where legally mandated.
8. International Data Transfers
If we transfer your personal information internationally, we ensure adequate safeguards per applicable law — such as standard contractual clauses or binding corporate rules — to protect your data during cross-border transmission.
9. Updates to this Privacy Policy
We review and update this Policy regularly to reflect operational, legal, or technological changes.
Material changes will be communicated with at least 30 days’ prior notice via email or prominent website notices before taking effect.
Continued use of our services after notification constitutes acceptance.
10. Contact Us
For questions, to exercise your rights, or to raise concerns, please contact:
The Top Minds Strategists, HWH Inc.
Email: [email protected]
Phone: +1 888-896-8858
Address: 8 The Green, STE A, Dover, DE 19901
11. Arbitration and Dispute Resolution
Privacy disputes shall be resolved through binding arbitration consistent with our Terms & Conditions arbitration provision.
Regulator Rights
Nothing in this section limits your right under applicable law to lodge complaints with data protection or regulatory authorities, or to pursue remedies available under state or federal law.
