1. Overview

The Manager of [Onepillar Holdings LLC] ("the Manager") personally oversees the collection, management, and protection of all information across business operations and subsidiaries.

2. Information Collection

The Manager collects and maintains:

• Financial records of all subsidiaries
• Business performance metrics
• Employee data
• Client/customer information
• Vendor relationships
• Corporate documentation
• Regulatory compliance records

3. Purpose of Collection

The Manager collects information to:

• Make informed investment decisions
• Monitor subsidiary performance
• Ensure regulatory compliance
• Manage business relationships
• Guide strategic planning
• Maintain accurate financial records

4. Information Storage and Security

The Manager maintains:

• A secure, centralized digital storage system
• Physical documentation in a secured location
• Password-protected access to all digital files
• Regular backup of all critical data
• Encrypted communication channels

5. Information Sharing

Information is shared:

• Only when legally required
• With authorized professional service providers (accountants, lawyers)
• Between subsidiaries on a need-to-know basis
• With regulatory bodies as required by law

6. Subsidiary Privacy Management

For each subsidiary under management, the Manager ensures:

• Individual privacy protocols are established
• Data sharing is strictly controlled
• Local management receives only necessary information
• Confidential information remains compartmentalized

7. Data Rights and Access

All stakeholders have the right to:

• Request access to their personal information
• Request correction of inaccurate data
• Understand how their information is used
• Object to certain data processing activities

8. Compliance Measures

The Manager ensures:

• Regular privacy audits
• Updated security measures
• Compliance with relevant regulations
• Proper documentation of all privacy-related decisions
• Timely response to privacy concerns

9. Risk Management

The Manager conducts:

• Regular risk assessments
• Implementation of necessary security updates
• Monitoring for potential privacy breaches
• Maintenance of incident response procedures
• Regular review and updates of privacy measures

10. Contact Information

For privacy-related inquiries:

• Direct communication channel to the Manager
• Guaranteed response within [X] business days
• Clear process for handling privacy concerns
• Documentation of all privacy-related communications

11. Updates and Changes

This privacy policy is:

• Reviewed quarterly by the Manager
• Updated as needed based on operational changes
• Modified to reflect new regulatory requirements
• Communicated to all stakeholders when updated

12. Accountability

The Manager assumes full responsibility for:

• Privacy policy implementation
• Data protection measures
• Regulatory compliance
• Privacy-related decisions
• Stakeholder communications

This privacy policy reflects the Manager's commitment to protecting the privacy and security of all information under management while maintaining efficient business operations across all subsidiaries.

Last Updated: 4-25-2025

Contact: hello@onepillarholdings.com