Effective & Last Updated: January 19, 2026

THE LOCKETT CIRCLE

GLOBAL PRIVATE CLIENT NOTICE OF PRIVACY POLICY AND CONFIDENTIALITY PRACTICES

At The Lockett Circle, privacy is not simply a policy — it is a core element of our service philosophy. We are entrusted with highly personal, financial, and lifestyle-related information, and we treat that responsibility with the highest level of discretion, professionalism, and care.

This notice explains how your information is handled in connection with bespoke trust, advisory, investment, real estate, hospitality and other related services.

OUR COMMITMENT TO DISCRETION

Your relationship with The Lockett Circle is confidential by design.
We limit access to your information strictly to professionals who require it to deliver your requested services, and we do not disclose client relationships or engagements for promotional or marketing purposes without explicit authorization.

INFORMATION WE MAY COLLECT

To provide tailored, high-touch services, we may collect:

  • Identity and contact details

  • Financial and transactional information

  • Investment, property, or asset-related data

  • Travel, hospitality, and lifestyle preferences (where relevant)

  • Donor or philanthropic engagement details

  • Communications and service instructions

  • Verification and compliance documentation where legally required

Information is collected directly from you, your authorized representatives, or from trusted professional counterparties acting on your behalf.

HOW YOUR INFORMATION IS USED

Your information is used exclusively for purposes such as:

  • Delivering personalized advisory and concierge services

  • Structuring and administering investments and property interests

  • Managing transactions, agreements, and registry services

  • Coordinating hospitality, residential, or lifestyle arrangements

  • Supporting philanthropic initiatives and donor intent

  • Meeting legal, regulatory, and fiduciary obligations

We do not sell personal data and do not engage in consumer advertising based on client profiles.

LIMITED AND CONTROLLED DISCLOSURE

When necessary to fulfill your instructions or comply with law, information may be shared under strict confidentiality with:

  • Internal Lockett Circle divisions and leadership teams

  • Legal, tax, and financial advisors

  • Custodians, registrars, and financial institutions

  • Property managers, developers, and hospitality partners

  • Regulatory or governmental authorities when required

All partners and service providers are contractually bound to confidentiality and data protection standards consistent with financial-services and private-client environments.

DATA RETENTION

We retain personal information only as long as necessary to:

  • Fulfill contractual services

  • Meet regulatory and legal obligations

  • Resolve disputes

  • Enforce agreements

DATA SECURITY

We maintain enterprise-grade safeguards including:

  • Secure, encrypted systems

  • Restricted internal access protocols

  • Partner security assessments

  • Confidentiality agreements for all personnel

  • Ongoing security monitoring and incident response procedures

These measures are designed to align with best practices in financial, legal, and private wealth management sectors.

YOUR PRIVACY RIGHTS

Subject to applicable law, you may request to:

  • Access your personal information

  • Correct or update records

  • Request deletion where legally permitted

  • Restrict or object to certain processing

  • Withdraw consent where applicable

  • Receive date portability

Requests are handled discreetly and verified to protect against unauthorized disclosure.

NOTICE TO CALIFORNIA RESIDENTS

California residents have rights to:

  • Know what personal data is collected and shared

  • Request deletion

  • Correct inaccurate information

  • Limit use of sensitive personal data

  • Opt out of selling or sharing (we do not sell or share for advertising)

We do not discriminate for exercising privacy rights.

INTERNATIONAL CLIENTS

As a global organization, your information may be processed in multiple jurisdictions.
We apply appropriate safeguards to protect international data transfers in accordance with applicable privacy laws and cross-border data protection frameworks.

CHILDREN’S PRIVACY

Our services are not directed to individuals under 18. We do not knowingly collect children’s data.

POLICY UPDATES

We may update this policy periodically. Updates will be posted with a revised effective date.

CONTINUITY OF CONFIDENTIALITY

Our obligation to confidentiality continues beyond the conclusion of any engagement, subject to legal and regulatory retention requirements.

CONTACT — PRIVATE CLIENT PRIVACY

For confidential privacy inquiries:

The Lockett Circle
Email: globallegal@lockettcircle.com
Mail: 1580 North Logan Street, Suite 660, Denver, Colorado 80203