Established January 1, 2018
For the Year Ended December 31, 2021

Promus Asset Management, LLC
8226 Douglas Avenue, Suite 650
Dallas, Texas 75225

Welcome to This site is subject to the following Terms of Service (“TOS”), which may be updated by us from time to time without notice to you. By accessing and using this website, you accept and agree to be bound by the terms and provisions of the TOS.


WEBSITE PRIVACY POLICY created this privacy policy in order to demonstrate our firm commitment to our visitors’ and participants’ privacy. The following discloses our information gathering and dissemination practices for

Non-Personal Information

During your visit to the site, we may request non-personally identifiable demographic and profile data, though providing this information is optional. We may use this data to improve our site and enhance your experience. We may use your IP address to help diagnose problems with our server, and to administer our site. Your IP address is used to help identify you for the duration of a session and to gather broad demographic information.

As you browse the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes called “clickstream” data, can be collected and stored by a website’s server. Clickstream data can tell us the type of computer and browsing software you use, the address of the website from which you linked to the site, and in some instances, your e-mail address. We may use clickstream data to determine how much time visitors spend on each page of our site and how they navigate throughout the site. We will only use this information to improve the site.

Personal Information

When you opt-in at our site as an Interested Party, you may be asked to provide certain personally identifiable information about yourself, such as your name, company name, job title, email address and certain information about your business and preferences. You may also be given the option of providing additional personal information such as your URL, phone and fax number and mailing address.

We use personal information provided by Interested Parties to notify Interested Parties about opportunities, properties, deliver newsletters and otherwise communicate with Interested Parties about and its properties and services. will not share any personal information of its Interested Parties with any unaffiliated third parties, without your consent.

Consent to Processing

By providing any personal information to this site, you fully understand and unambiguously consent to the collection and processing of such information in the United States and/or any other country.

Other Sites

Our site may contain links to other sites. Other sites may also reference or link to our site. is not responsible for the privacy practices or the content of such other sites.


We take seriously the security for all personal and non-personal information associated with our visitors and participants by using secure communications for all such data. However, due to the open communication nature of the Internet, we cannot guarantee that communications between you and, and and you, will be free from unauthorized access by third parties.


If we ever send you information by e-mail concerning products or services, we will provide you with an e-mail address by which you may request no future notices.

Your Acceptance of this Policy

By visiting this site or receiving Services, you signify your assent to our then current Privacy Policy. If you do not agree to this policy, please do not use our site or Services. We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time. Your continued use of our site following the posting of changes to these terms means you accept these terms.



The Company views protecting private information regarding its clients and potential clients as a top priority. Pursuant to the requirements of the Gramm-Leach-Bliley Act (the “GLBA”) and guidelines established by the Securities Exchange Commission regarding the Privacy of Consumer Financial Information (Regulation S-P), the Company has instituted the following policies and procedures in an effort to ensure that such nonpublic private information is kept private and secure. This policy also
outlines what the Company and its Associated Persons are allowed to use the confidential personal information collected in connection with its advisory activities.

This Privacy Policy covers the practices of the Company and applies to all nonpublic personally identifiable information, including information contained in consumer reports, of our current and former clients.


The CCO is responsible for administering the Company’s policies on safeguarding and protecting the nonpublic personal information of clients collected by the Company, and to ensure that nonpublic personal information of the Company’s clients is shared only with Associated Persons and others in a way that is consistent with the Company’s Privacy Notice and the procedures contained in this Policy.

  • Each Associated Person has a duty to protect the non public personal information of clients collected by the Company.
  • Each Associated Person has a duty to ensure that nonpublic personal information of the Company’s clients is shared only with Associated Persons and others in a way that is consistent with the Company’s Privacy Notice and the procedures contained in this Policy.
  • Each Associated Person has a duty to ensure that access to nonpublic personal information of the Company’s clients is limited as provided in the Privacy Notice and this Policy.
  • No Associated Person is authorized to sell, on behalf of the Company or otherwise, nonpublic information of the Company’s clients.
  • Associated Person with questions concerning the collection and sharing of, or access to, nonpublic personal information of the Company’s clients must look to the Company’s CCO for guidance.
  • Violations of these policies and procedures will be addressed in a manner consistent with other Company disciplinary guidelines.

Associated Persons with questions concerning the collection and sharing of, or access to, nonpublic personal information of the Company’s clients must look to the Company’s CCO for guidance. Violations of these policies and procedures will be addressed in a manner consistent with other Company disciplinary guidelines.

Information Practices

The Company limits the use, collection, and retention of client or potential client information to what we believe is necessary or useful to conduct our business or to offer quality products, services, and other opportunities that may be of interest to our clients or potential clients.

The Company collects nonpublic personal identifying information about its clients and/or potential clients such as name, address, telephone number, social security number or taxpayer ID number, date of birth, employment status, annual income, and net worth.

The information is collected when the client completes account opening documents, signs our agreement for services, and through the client’s account custodian or other authorized representatives, e.g. attorney, accountant, bank, etc.

Disclosure of Information to Nonaffiliated Third Parties – “Do Not Share” Policy

The Company has a “do not share” policy. We do not disclose nonpublic personal information to nonaffiliated third parties, except under one of the GLBA privacy exceptions, as described below. Since the Company currently operates under a “do not share” policy, it does not need to provide the right for its clients to opt out of sharing with nonaffiliated third parties, as long as such entities are exempted as described below. If our information sharing practices change in the future, we will
implement opt out policies and procedures, and we will make appropriate disclosures to our clients.

Types of Permitted Disclosures – The Exceptions

In certain circumstances, Regulation S-P permits the Company to share nonpublic personal information about its clients with nonaffiliated third parties without providing an opportunity for those individuals to opt out. These circumstances include sharing information with a non-affiliate (1) as necessary to effect, administer, or enforce a transaction that a client requests or authorizes; (2) in connection with processing or servicing a financial product or a service a client authorizes; and (3) in
connection with maintaining or servicing a client account with the Company.

Service Providers

From time to time, the Company may have relationships with nonaffiliated third parties (such as attorneys, auditors, accountants, brokers, custodians, and other consultants), who, in the ordinary course of providing their services to us, may require access to information containing nonpublic information. These third-party service providers are necessary for us to provide our investment advisory services. When we are not comfortable that service providers (e.g., attorneys, auditors, and other financial institutions) are already bound by duties of confidentiality, we require assurances from
those service providers that they will maintain the confidentiality of nonpublic information they obtain from or through us. In addition, we select and retain service providers that we believe are capable of maintaining appropriate safeguards for nonpublic information, and we will require agreements from our service providers that they will implement and maintain such safeguards.

Processing and Servicing Transactions

The Company may also share information when it is necessary to effect, administer, or enforce a transaction requested or authorized by clients. In this context, “necessary to effect, administer, or enforce a transaction” includes what is required or is a usual, appropriate, or acceptable method:

  • To carry out the transaction or the product or service business of which the transaction is a part, and record, service, or maintain the client’s account in the ordinary course of providing the financial service or financial product;
  • To administer or service benefits or claims relating to the transaction or the product or service of which it is a part;
  • To provide a confirmation, statement, or other record of the transaction, or information on the status or value of the financial service or financial product to the client or the client’s agent or broker.

Sharing as Permitted or Required by Law

The Company may disclose information to nonaffiliated third parties as required or allowed by law. For example, this may include disclosures in connection with a subpoena or similar legal process, a fraud investigation, recording of deeds of trust and mortgages in public records, or an audit or examination.

Provision of Opt Out

As discussed above, the Company does not share nonpublic client information with unaffiliated third parties beyond the available exemptions provided under applicable privacy regulations.

Disclosure of Information to Affiliated Third Parties

The Company may share information with affiliated parties and shall inform clients, in its privacy notice, of the type of information shared and the category of parties with whom such information is shared. Client information may be shared for legitimate business purposes only.

Privacy Notice

The Company has developed a Privacy Notice, as required under Regulation S-P, to be delivered to clients initially and to current clients on an annual basis. The notice discloses the Company’s information collection and sharing practices and other required information. The notice will be revised as necessary any time information practices change.

Privacy Notice Delivery

  • Initial Privacy Notice – As regulations require, all new clients receive an initial Privacy Notice at the time the client relationship is established (i.e., upon execution of the agreement for services),
  • Annual Privacy Notice – Pertinent regulations require that disclosure of the Privacy Policy be provided to existing clients on an annual basis. The Company will deliver its annual Privacy Notice in conjunction with the annual offer of its Disclosure Brochure.

Revised Privacy Notice

Regulation S-P requires that the Company amend its Privacy Policy and promptly distribute a revised disclosure to clients, if there is a change in the Company’s collection, sharing, or security practices.

Joint Relationships

If two or more individuals jointly obtain a financial product or service from the Company, the Company may satisfy the initial, annual, and revised notice requirements by providing one notice to those individuals jointly.

Should you have any questions regarding this disclosure, please contact Brandon K Pope, President of Promus Asset Management, LLC.