Privacy Policy

Esphera App

Last updated: 12/2025

Esphera Capital (“Esphera”, “we”, “our”, or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Esphera mobile application (the “App”). By using the App, you consent to the practices described in this Privacy Policy.

1. Information We Collect

We may collect the following categories of information:

1.1 Personal Information Provided by You

This includes information you provide directly in the App:

  • Account numbers or identifiers

  • External account details (with your authorization)

  • Requests for transfers, travel or purchase notes, and other operational instructions

  • Documents or information uploaded by you

1.2 Portfolio and Financial Information

To provide the App’s core features, we collect and display:

  • Portfolio balances

  • Asset class allocations

  • Holdings and security details

  • Performance metrics

  • Activity history (dividends, interest credits, tax withholdings, wires, and similar)

This information is obtained through authorized integrations with custodians and service providers such as Masttro.

1.3 Authentication and Security Information

Collected through your use of login and verification features:

  • Device identifiers

  • Login credentials

  • Biometric authentication tokens (Face ID or similar, where available)

We do not store your biometric data; the device’s secure system manages it.

1.4 Usage Data

Automatically collected when interacting with the App:

  • Device type and operating system

  • App version

  • Log data, analytics, and crash reports

2. How We Use Your Information

We use your information to:

  • Present accurate and up to date portfolio information

  • Process your requests, including wire transfers, account openings, and other operational instructions

  • Provide reporting and consolidations of external accounts

  • Improve App performance, security, and user experience

  • Respond to customer support inquiries

  • Comply with legal and regulatory obligations

We do not sell or rent your personal information.

3. How We Share Your Information

We may share your information only as necessary:

3.1 Service Providers

Trusted third parties that support the App, such as:

  • Data aggregation platforms

  • Custodians and banks

  • Cloud hosting providers (e.g., AWS)

  • Identity and authentication services (e.g., Cognito)

These providers are bound by confidentiality obligations.

3.2 Regulatory or Legal Requirements

We may disclose information to:

  • Comply with applicable laws or requests from regulatory authorities

  • Protect the rights, property, or safety of Esphera or its clients

3.3 At Your Direction

Certain actions in the App (such as a wire request) may require sending documentation to you or designated parties, including via email, or other channels you authorize.

4. Data Security

We use industry standard technical and organizational measures to safeguard your information, including:

  • Encryption in transit and at rest

  • Secure authentication protocols

  • Strict access controls

  • Monitoring and audits

While we take reasonable steps to protect your information, no system can guarantee absolute security.

5. Data Retention

We retain your information for as long as necessary to:

  • Provide the App services

  • Meet regulatory recordkeeping requirements

  • Resolve disputes or enforce agreements

6. Cryptocurrency and Asset Trading

The Esphera Capital mobile application does not provide cryptocurrency exchange, trading, swapping, or brokerage services.

Users cannot execute any form of purchase, sale, transfer, swap, withdrawal, or deposit of cryptocurrency or digital assets through this application.

All investment transactions, including any potential trading or exchange services, are executed offline through Esphera Capital’s licensed financial services platform or advisors, and not through this mobile app.

This app is strictly a portfolio reporting and account overview tool for existing Esphera Capital clients.

7. Your Choices and Rights

Depending on your jurisdiction, you may have rights such as:

  • Accessing your personal information

  • Requesting corrections

  • Requesting deletion where legally permissible

  • Withdrawing consents previously granted

To exercise these rights, contact us at: apprequests@espheracapital.com

8. External Accounts and Consents

When you link external accounts through the App, you authorize Esphera to access and display data from those accounts. You may revoke these permissions at any time.

The App does not conduct transactions on external accounts without your explicit and documented authorization.

9. International Transfers

Your information may be processed in jurisdictions where our service providers operate. These jurisdictions may have different data protection standards. We take measures to ensure your data remains protected.

10. Children’s Privacy

The App is not intended for individuals under 18. We do not knowingly collect information from minors.

11. Updates to This Privacy Policy

We may update this Privacy Policy periodically. Changes become effective when posted in the App. Continued use constitutes acceptance.

12. Contact Us

For questions about this Privacy Policy or your personal information, contact us at:
apprequests@espheracapital.com
1441 Brickell Avenue, Suite 1700, Miami, FL 33131
+1 786 801 2331