Effective Date: January 16, 2026 | Last Updated: January 16, 2026
YOUR PRIVACY MATTERS
Dombey Capital Management ("Dombey Capital," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our platform.
This Privacy Policy applies to all users of the Dombey Capital website, member portal, research platform, email subscriptions, and related services (collectively, the "Platform"). By accessing or using the Platform, you consent to the data practices described in this Privacy Policy.
Data Controller: Dombey Capital Management is the data controller responsible for your personal information. We are based in San Francisco, California, United States.
This Privacy Policy complies with the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and the General Data Protection Regulation (GDPR) for applicable users.
We collect several categories of personal information to provide and improve our services:
When you access the Platform, we automatically collect certain information through cookies, log files, and analytics tools:
We use Firebase (a Google service) for platform infrastructure. Firebase collects and processes:
Google acts as a data processor for Firebase services. Data is stored on Google Cloud servers, primarily in the United States. See Google's Firebase Privacy Documentation for more information.
We use your personal information for the following purposes:
Legal Basis (GDPR): Contractual necessity – necessary to perform our agreement with you.
Legal Basis (GDPR): Contractual necessity (service-related emails), Legitimate interests (customer support), Consent (marketing emails, if applicable).
Legal Basis (GDPR): Legitimate interests – improving our services and user experience.
Legal Basis (GDPR): Legitimate interests – protecting our platform and users.
Legal Basis (GDPR): Legal obligation.
We do not sell your personal information. We share personal information only in the following limited circumstances:
We share personal information with third-party service providers who perform services on our behalf:
These service providers are contractually obligated to protect your data and use it only for the purposes we specify.
We use third-party APIs to fetch curated intelligence reports. We do not share your personal information with these third-party intelligence providers. Our API requests use authentication keys and do not transmit user-identifiable data.
In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the successor entity. We will notify you of any such change in ownership or control.
We may disclose personal information if required by law, court order, subpoena, or government request, or if we believe disclosure is necessary to protect our rights, prevent fraud, or ensure safety.
Your personal information is stored on Google Cloud servers located primarily in the United States. If you access our Platform from outside the United States, your data will be transferred to and processed in the United States.
For EU/EEA/UK users: We rely on Google's Standard Contractual Clauses (SCCs) approved by the European Commission to safeguard data transfers. See Google Cloud GDPR Compliance.
Cookies are small text files stored on your device that help us recognize you, remember preferences, and analyze usage. We use both first-party cookies (set by Dombey Capital) and third-party cookies (set by service providers like Firebase).
You can control cookies through your browser settings:
We retain personal information only as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.
Upon account deletion or data retention expiration, we securely delete or anonymize your personal information.
Depending on your location, you may have the following rights regarding your personal information:
To exercise any of these rights, please contact us:
Response Timeline: We will respond to verified requests within 30 days (GDPR) or 45 days (CCPA). We may request additional information to verify your identity before processing requests.
We implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, disclosure, alteration, or destruction, including:
However, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials.
Breach Notification: In the event of a data breach affecting your personal information, we will notify you and applicable regulators as required by law (e.g., within 72 hours under GDPR, or as required by California law for breaches affecting 500+ residents).
Our Platform is not directed to individuals under the age of 18 (or 16 for GDPR purposes). We do not knowingly collect personal information from children. If we discover that we have collected information from a child, we will delete it immediately. If you believe we have collected information from a child, please contact us at privacy@dombey.capital.
The Platform may contain links to third-party websites, research sources, or external services (e.g., Substack, intelligence providers). We are not responsible for the privacy practices or content of third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.
Our Platform is primarily intended for users in the United States. If you access the Platform from outside the U.S., you acknowledge that your personal information will be transferred to and processed in the United States, which may have different data protection laws than your country.
EU/EEA/UK Users: If you are located in the EU, EEA, or UK, you have the right to lodge a complaint with your local supervisory authority if you believe we have violated data protection laws.
California Civil Code Section 1798.83 permits California residents to request information about our disclosure of personal information to third parties for direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes. If you have questions, contact us at privacy@dombey.capital.
We reserve the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or Platform features. If we make material changes, we will notify you by:
Your continued use of the Platform after changes take effect constitutes acceptance of the updated Privacy Policy. We recommend reviewing this page annually and whenever you notice the "Last Updated" date has changed.
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Dombey Capital Management
Privacy Contact: privacy@dombey.capital
General Inquiries: support@dombey.capital
Mailing Address: San Francisco, CA
For EU/EEA/UK Users: You have the right to lodge a complaint with your local data protection supervisory authority if you believe we have violated your data protection rights.
ACKNOWLEDGMENT: By using the Dombey Capital Platform, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy.
Effective Date: January 16, 2026
Last Updated: January 16, 2026