Exodus Business Management Group, LLC (“EBMG,” “us,” “we” or “our”) is committed to maintaining the confidentiality of the personal information of our clients, employees, and website visitors. This Privacy Policy (together with our Terms of Use and any other policies referenced) identifies how we will collect and handle any personal information that we collect from you, or that you provide to us.

 

If you are a California resident, our privacy practices comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”). Explanation of your rights under the CCPA can be found here.

 

If you are a resident of the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, this Privacy Policy also outlines additional policies applicable to our collection and processing of your personal information, which can be found here. Non-EEA countries do not have the same data protection laws as the United Kingdom, Switzerland and EEA. We will, however, take steps to ensure that any transfer of personal information will be secure and complies with applicable data protection laws.

 

SMS Consent: By providing your consent to receive SMS/text messages from EBMG, you are agreeing to receive messages exclusively from us. Your SMS consent is not shared with or sold to third parties. Any third parties with whom EBMG may do business are required to obtain their own consent to send SMS/text messages to you.

 

As our services evolve and we perceive the need or desirability of using your personal data collected in other ways, we may from time to time amend this Privacy Policy. The effective date appears at the end of this Privacy Policy. We encourage you to check our Site frequently to review the current Privacy Policy in effect and any changes that may have been made to it.

 

  1. Introduction

This Privacy Policy describes how EBMG collects, uses, and shares personal information of our clients, prospective employees, visitors to our website at www.ebmg.com (“Site”), EBMG Client Portal (“App”), and individuals who contact us to request information. The Website and our other programs and services are referred to in this Privacy Policy as the “Services.” This Policy describes how we collect and use personal information (information which can be used to identify a specific individual) and anonymous data (which cannot be used to identify a specific individual).

 

Notice at Collection. Every time we ask you to provide personal information on the Site, we are collecting information that is subject to this Privacy Policy.

 

Region specific provisions. Certain provisions of this Policy, which are clearly labelled, apply only to users who are citizens or residents of particular regions (e.g., the EU or California). Otherwise, this Policy applies to all users of our Services, regardless of location.

 

Children. Our Services are not directed to children. See Protecting children’s privacy below.

 

  1. What Personal Information does EBMG collect?

For purposes of this Policy, “Personal Information” means information (whether stored electronically or in paper-based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession). The table below describes the categories of Personal Information we may collect.

 

Category

Description

Identifiers

Name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, SSN, driver’s license or identification card number, or passport number.

Protected Classes

Race, age, gender, citizenship, national origin, marital status, medical condition, disability, sexual orientation, or veteran status.

Commercial Information

Records of personal property, purchasing or consuming histories, tendencies, or investment portfolios.

Biometric Information

Fingerprints or activity patterns used to extract templates for identification.

Internet Activity

Browsing history, search history, IP address, and website interactions with the EBMG portal.

Geolocation Data

Precise location, movements, or GPS coordinates.

Sensory Data

Audio, electronic, visual, or similar information.

Professional Data

Current or past job history, performance evaluations, or union/guild membership data.

Education Data

Educational background, grades, scores, or accreditation status.

Other Data

Financial information, tax returns, bank statements, or health insurance information.

Inferences

Profiles drawn reflecting a person’s preferences, psychological trends, and predispositions.

 

2.1 Personal Information and Sensitive Personal Information

EBMG collects only that Personal Information that is relevant for the purposes for which the data is requested. EBMG does not use your Personal Information in any way that is incompatible with the purposes for which it was collected.

 

Some categories include “Sensitive Personal Information,” which EBMG may collect, including: identifiers (SSN, passport); financial account logins and credentials; racial or ethnic origin; religious beliefs; union membership; and contents of communications unless EBMG is the intended recipient.

 

2.2 Personal Information Collected about Clients

We collect non-public personal information about you from documents you provide, such as tax returns, contracts, and bank and investment statements. We may also receive information from your attorneys, banks, financial institutions, and other sources with your express consent.

 

2.3 Personal Information Collected about Prospective Employees

We collect Personal Information from individuals entering information within the EBMG employment portal. We do not collect Commercial Information, Biometric Information, Internet Activity or Sensory Data from prospective employees.

 

2.4 Personal Information Collected about Website Visitors or Callers

Our web server automatically collects browser type, IP address, device identifiers, referring website, and time of access. We use cookies and pixel tags (including Google Analytics) to determine statistics about website visits from certain geographic regions. You can block cookies through your browser settings.

 

  1. How does EBMG use Personal Information?

3.1 Personal Information Collected about Clients

We use this information to:

  • Provide you with requested Family Office and Business Management Services.

 

  • Carry out contractual obligations.

 

  • Contact you about other products, services, or tax insights.

 

  • Notify you of changes to our systems or Services.

 

  • Comply with laws and regulatory requirements.

 

3.2 Personal Information Collected about Prospective Employees

We use this information to respond to job applications and make inquiries for credit and reference purposes.

 

3.3 Personal Information Collected about Website Visitors or Callers

We use this information to provide requested information and improve our site safety and presentation.

 

  1. Do we disclose your Personal Information to any third parties?

4.1 Personal Information Collected about Clients

EBMG does not sell your Personal Information or share it for third-party advertising. We may share information with service providers and contractors to provide the Services, subject to written agreements restricting use, sale, or sharing of your data.

 

Other circumstances for sharing include:

  • Merger or Sale: Prospective purchase, sale, or merger of all or part of our practice, subject to confidentiality agreements.

 

  • Legal Proceedings: Connection with actual or threatened legal proceedings or alternative dispute resolution.

 

  • Legal Obligations: Compliance with legal obligations, national security, or law enforcement requirements.

 

4.2 Personal Information Collected about Prospective Employees

We only disclose Personal Information about applicants as permitted by law to verify application details or perform consented credit checks.

 

4.3 Personal Information Collected about Website Visitors or Callers

We do not disclose Personal Information collected from visitors or callers seeking information about our Services to third parties.

 

  1. Our storage of your Personal Information

EBMG uses reasonable and appropriate measures to protect your Personal Information from loss, misuse, and unauthorized access. We keep your Personal Information for as long as needed for the purposes set out above or as prescribed by law. You may contact us for a copy of our record retention policy.

 

  1. Access to other websites

Our Site may include links to third-party websites. These websites are not covered by this Privacy Policy, and EBMG is not responsible for their privacy practices.

 

  1. Protecting children’s privacy

Our Site is not intended for use by children under 13. We do not knowingly collect personal information from children under 13 and comply with COPPA.

 

  1. Additional Policies for California Residents

Subject to certain exceptions under the CCPA, California consumers have the right to request disclosure of collected info, request deletion, correct inaccurate data, and limit the use of Sensitive Personal Information. To submit a request, contact us at (877) 555-EBMG or ConsumerRequest@ebmg.com.

 

  1. Additional Policies for Residents of EEA, UK and Switzerland

Under the GDPR, EBMG is a “Controller”. We process your data based on legitimate business interests, performance of a contract, your consent, or compliance with legal obligations. You have the right to access, correct, erase, or object to the processing of your Personal Information.

 

  1. Conditions of use and changes to our Privacy Policy

Your use of our Services is subject to this Policy and our Terms of Use, including application of the law of the State of California. As our business changes, our Privacy Policy and Terms of Use may change as well.

 

  1. Contacting us

This Site is owned and operated by Exodus Business Management Group, LLC. If you have any questions, please contact us at:

 

Exodus Business Management Group, LLC

3950 Laurel Canyon Boulevard

Studio City, CA 91604

(877) 555-EBMG

ConsumerRequest@ebmg.com

 

CCPA-Specific Requests

Please submit CCPA-specific data requests through the procedures set forth in Section 8.

 

GDPR/UK/Swiss-Specific Requests

For residents of the EEA, the UK or Switzerland, please contact Matt Kirk, at dataprotection@rossbennetsmith.com or telephone at 020 7930 6000.

 

Updated February 23, 2026

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