Privacy Policy
PRIVACY POLICY
Craft Financials, Inc. and Affiliates
Effective Date: May 7, 2026
1. Introduction
This Privacy Policy ("Policy") describes how Craft Financials, Inc. ("Craft Financials," "we," "us," or "our") and its affiliated companies—Pod Securities, LLC ("Pod Securities"), Craft Advisors, LLC ("Craft Advisors"), and Craft Charter, LLC ("Craft Charter") (collectively, the "Craft Companies")—collect, use, share, and protect personal information about our current, prospective, and former customers, website visitors, and other individuals who interact with us.
This Policy applies to information we collect through www.flycraft.com (the "Site"), through our mobile and web applications, when you open or maintain an account with any of the Craft Companies, or when you otherwise communicate with us. By using our Site or services, you acknowledge that you have read and understood this Policy.
Pod Securities and Craft Advisors are subject to specific federal financial-privacy laws, including the Gramm-Leach-Bliley Act ("GLBA") and the SEC’s Regulation S-P. Where those laws apply, the entity-specific notices in Sections 9 and 10 govern, and this Policy as a whole supplements (but does not replace) those notices.
2. The Craft Companies
Craft Financials, Inc. is the parent holding company of the entities listed below. Each affiliated entity is a separate legal entity and provides distinct services subject to different regulatory regimes.
Pod Securities, LLC — a broker-dealer registered with the U.S. Securities and Exchange Commission (“SEC”) and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”).
Craft Advisors, LLC — an investment adviser registered with the SEC under the Investment Advisers Act of 1940.
Craft Charter, LLC — an air carrier certificated by the Federal Aviation Administration (“FAA”) under 14 C.F.R. Part 135, providing on-demand charter air transportation.
Where we refer to a specific Craft Company, only the disclosures applicable to that entity apply. Where we refer to the Craft Companies collectively, the disclosures apply to all of us.
3. Information We Collect
The categories of personal information we collect depend on the services you request, your relationship with us, and how you interact with our Site. We collect information from the following categories:
3.1 Identifiers and Contact Information
Name, mailing and email addresses, telephone numbers, date of birth, government-issued identification numbers (including Social Security number or taxpayer identification number), passport, driver’s license number, and online identifiers.
3.2 Financial Information
Bank and brokerage account numbers, account balances, transaction history, source of funds, net worth, income, investment objectives, risk tolerance, tax information, and credit history.
3.3 Employment and Background Information
Employer, occupation, employment status, professional affiliations (including any FINRA association), and information collected for know-your-customer, anti-money-laundering, and customer due-diligence purposes.
3.4 Transactional and Account Activity
Trade and order history, securities holdings, advisory account performance, charter flight bookings, passenger manifests, itineraries, and communications with our personnel.
3.5 Online and Device Information
IP address, browser type, device identifiers, operating system, referring URLs, pages viewed, time spent on the Site, and information collected through cookies, pixels, and similar technologies (see Section 11).
3.6 Sensitive Personal Information
Some of the information above (e.g., Social Security number, financial account log-in credentials, government identifiers, and precise geolocation collected when you book or take a flight) is treated as “sensitive personal information” under California law. We use sensitive personal information only for the purposes described in Section 5 and as otherwise permitted by law. We do not use or disclose sensitive personal information to infer characteristics about you.
3.7 Information from Third Parties
We may receive information about you from your employer or plan sponsor, custodians, clearing firms, joint account holders, banks, credit bureaus, identity-verification and fraud-prevention vendors, regulators, public databases, and our affiliates. For Craft Charter, we may receive information from travel agents, travel-management companies, and aircraft owners participating in management or charter programs.
4. Sources of Personal Information
We collect personal information from the following sources:
Directly from you, including in account-opening applications (paper or electronic), client agreements, charter requests, surveys, and your communications with us.
Automatically through your use of the Site or our applications.
From our affiliates and from non-affiliated third parties such as custodians, banks, credit bureaus, identity-verification vendors, government agencies, and public sources.
5. How We Use Personal Information
We use personal information for the following business purposes:
To open, maintain, and service your accounts and to process your transactions, including securities trades, advisory transactions, and charter flight bookings.
To verify your identity and to comply with anti-money-laundering, know-your-customer, sanctions, customer due-diligence, and counter-terrorism financing laws.
To comply with our legal, regulatory, recordkeeping, and reporting obligations under federal and state securities laws, FINRA rules, the Bank Secrecy Act, the Investment Advisers Act of 1940, FAA regulations, and applicable tax laws.
To detect, investigate, and prevent fraud, security incidents, and other unlawful or harmful activity, and to safeguard our customers, employees, and assets.
To communicate with you about your account, your transactions, our services, and changes to our policies and disclosures.
To provide customer support and to respond to your questions, complaints, and requests.
To operate, maintain, and improve our Site, applications, and services, including for analytics, debugging, and product development.
With your consent, to send you marketing communications about products and services that may be of interest to you. You may opt out of marketing communications at any time.
To enforce our agreements with you, defend against legal claims, and otherwise protect our rights, property, and interests.
6. How We Share Personal Information
We share personal information only as described below and as permitted by applicable law. We do not sell your personal information for monetary consideration, and we do not share your personal information for cross-context behavioral advertising.
6.1 Among the Craft Companies
We share personal information among the Craft Companies for everyday business purposes, including to provide integrated client service across brokerage, advisory, and charter relationships, to comply with legal obligations, and to enable joint marketing where permitted.
6.2 Service Providers
We share personal information with non-affiliated service providers and contractors that perform services on our behalf, including custodians, clearing firms, banks, payment processors, technology and cloud-hosting vendors, identity-verification and fraud-prevention vendors, professional advisers, auditors, mailing-house and statement-processing vendors, marketing-platform providers, and aircraft management or operating partners. These parties are contractually limited to using personal information only for the services they perform for us.
6.3 Regulators, Law Enforcement, and Legal Process
We share personal information with the SEC, FINRA, SIPC, the FAA, state securities regulators, the Department of the Treasury (including FinCEN), the IRS, and other regulators, self-regulatory organizations, and law-enforcement authorities, and in response to subpoenas, court orders, or other legal process, when required or permitted by law.
6.4 Business Transfers
If any of the Craft Companies is involved in a merger, acquisition, financing, reorganization, sale of assets, or bankruptcy, we may share personal information with counterparties and their advisers as part of that transaction, subject to appropriate confidentiality protections.
6.5 With Your Direction or Consent
We will share personal information with any other party at your direction or with your consent, including third parties you authorize to access your account information.
7. How We Protect Your Information
It is our policy not to release your personal information except as permitted by law, with your consent, as requested by you, or as set forth in this Policy. Within the Craft Companies, we restrict access to your personal information to those employees, agents, and service providers who require it to provide products or services to you. To protect your personal information from unauthorized access and use, we maintain administrative, technical, and physical safeguards designed to comply with applicable federal and state laws, including the SEC’s Regulation S-P safeguarding requirements. These safeguards include access controls, encryption of sensitive data in transit and at rest, network monitoring, employee training, and secured files and facilities.
Pod Securities and Craft Advisors maintain a written incident-response program that is designed to detect, respond to, and recover from unauthorized access to or use of customer information, and to provide notice to affected individuals as required by Regulation S-P and applicable state breach-notification laws.
8. Data Retention
We retain personal information for as long as necessary to provide our services and to comply with our legal, regulatory, accounting, recordkeeping, and reporting obligations. Retention periods are determined by reference to the type of information, the purpose for which it was collected, applicable books-and-records rules under SEC Rules 17a-3 and 17a-4 and Investment Advisers Act Rule 204-2, FAA recordkeeping requirements under 14 C.F.R. Part 135, applicable tax laws, and the statute of limitations for potential legal claims. Once retention is no longer required, we securely delete, de-identify, or anonymize the information.
9. Pod Securities, LLC — Regulation S-P / GLBA Privacy Notice
This Section 9 is the Privacy Notice of Pod Securities, LLC required by the Gramm-Leach-Bliley Act and the SEC’s Regulation S-P. It applies to current, prospective, and former customers of Pod Securities.
Privacy Statement
Pod Securities LLC (the “Firm”) is committed to maintaining the confidentiality, integrity and security of personal information about our current and prospective customers. We understand that privacy is an important issue for you, and we also want you to understand how we protect your privacy when we collect personal information about you.
Information We Collect
The personal information we collect from you comes from information you supply to us in account opening applications (whether written or electronic), or in other forms you may provide to us in the initial and periodic due diligence process. This information may include your name, address, social security number or tax identification number, account number, account balances and financial information about you.
Information We May Share
The Firm may share personal information about our current and former customers with our affiliated companies and service providers. We may share the information for everyday business purposes, including to process your transactions, or to assist us in providing services that may be of interest to you. We may also share personal information with non-affiliated companies that are required to process your transactions or provide other services. We do not sell your information or provide it to non-affiliated parties for marketing purposes. We may also disclose information about current or former customers in order to cooperate with legal or regulatory authorities or pursuant to a court order or subpoena. In addition, we may disclose personal information as necessary to perform credit checks, collect debts, enforce our legal rights or otherwise protect our interests and property.
How We Protect Your Information
It is our policy not to release your personal information except as permitted by law, with your consent, as requested by you or set forth below. Within the Firm, we restrict access to your personal information to those who require it to provide products or services to you. To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
Opt-Out Notice
The law allows you to “opt out” of our sharing nonpublic personal information about you in certain circumstances with affiliated and nonaffiliated companies; that is, you may direct us to not make such disclosures. We do not currently share information about you with any affiliate or third party that triggers this opt-out right. Therefore, there is no need for you to opt out. If in the future we desire to disclose your information in a way that is inconsistent with this policy, we will notify you in advance and provide you with the opportunity to opt out of such disclosure.
THIS PRIVACY NOTICE IS PROVIDED TO YOU FOR INFORMATIONAL PURPOSES ONLY. YOU DO NOT NEED TO CALL OR TAKE ANY ACTION IN RESPONSE TO THIS NOTICE. WE RECOMMEND THAT YOU READ AND RETAIN THIS NOTICE FOR YOUR PERSONAL RECORDS.
10. Craft Advisors, LLC — Investment Adviser Privacy Notice
Craft Advisors, LLC is an SEC-registered investment adviser. As a fiduciary, Craft Advisors is committed to safeguarding the personal information of its clients and prospective clients. This Section 10, together with Sections 1–8, constitutes the privacy notice that Craft Advisors delivers to its clients in connection with its Form ADV brochure and on an annual basis as required by Regulation S-P.
Craft Advisors collects personal information from clients and prospective clients on advisory account applications, in advisory agreements, and in connection with financial-planning, investment-management, and reporting services. The categories of information collected are described in Section 3 above.
Craft Advisors does not sell client personal information. Craft Advisors shares personal information with custodians, brokers (including Pod Securities), portfolio-management and reporting platforms, and other service providers as necessary to manage advisory accounts and to comply with the Investment Advisers Act of 1940 and other applicable laws. Craft Advisors makes its current Form ADV Part 2A brochure and this privacy notice available to clients without charge upon request.
11. Craft Charter, LLC — Air Carrier Privacy Practices
Craft Charter collects personal information necessary to provide on-demand charter air-transportation services under 14 C.F.R. Part 135, including the names of charterers and passengers, dates of birth, government-issued identification, contact information, weight (where required for weight-and-balance), itineraries, and special-handling or accommodation requests.
Craft Charter shares passenger manifests, identification information, and travel itineraries with the FAA, the Transportation Security Administration (“TSA”), U.S. Customs and Border Protection, foreign customs and immigration authorities, fixed-base operators, ground-handling providers, and aircraft owners or operators participating in management or charter programs, in each case as required to operate the flight, comply with applicable aviation and security regulations, and protect passenger safety.
12. Cookies and Tracking Technologies
Our Site uses cookies, web beacons, pixels, and similar technologies to operate the Site, remember your preferences, analyze usage, and measure the performance of our communications. We use both first-party and third-party cookies. You may disable cookies through your browser settings, but doing so may limit the functionality of the Site.
We honor browser-based opt-out preference signals (such as the Global Privacy Control) for California, Colorado, Connecticut, and other state-law residents whose laws require us to do so.
13. Your California Privacy Rights (CCPA / CPRA)
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), provides you with specific rights regarding your personal information. This section applies only to personal information that is not subject to the GLBA exemption (i.e., information collected outside of the financial-services context, such as Site-visitor or marketing-related data).
13.1 Categories of Personal Information We Collect, Disclose, and Retain
Within the prior 12 months, we have collected, used, and disclosed for business purposes the categories of personal information described in Section 3 (identifiers, customer records, commercial information, financial information, internet/network activity, geolocation, employment-related information, and sensitive personal information).
We retain each category for the period described in Section 8.
13.2 Sale and Sharing
We do not sell personal information for monetary consideration, and we do not share personal information for cross-context behavioral advertising. We have not sold or shared the personal information of consumers under 16 years of age.
13.3 Your Rights
Subject to verification and applicable exceptions, California residents have the right to:
Know the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collecting or sharing personal information, and the categories of third parties to whom we disclose personal information.
Delete personal information we have collected from you, subject to legal exceptions.
Correct inaccurate personal information we maintain about you.
Opt out of the sale or sharing of personal information (we do not engage in either).
Limit the use and disclosure of sensitive personal information.
Be free from retaliation for exercising any of these rights.
13.4 How to Exercise Your Rights
You may submit a request to know, delete, correct, or limit by emailing us at pod@flycraft.com, calling us at (310) 848-3636, or writing to us at the address in Section 19. We will verify your identity before responding. You may also designate an authorized agent to make a request on your behalf.
14. Other U.S. State Privacy Rights
Residents of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, and other U.S. states with comprehensive privacy laws may have rights similar to those described in Section 13, including rights to access, correct, delete, port, and opt out of targeted advertising and certain profiling. To exercise any such right, please contact us using the methods in Section 13.4.
15. Privacy Rights of EEA, U.K., and Swiss Residents (GDPR)
If you are located in the European Economic Area, the United Kingdom, or Switzerland, the General Data Protection Regulation (“GDPR”), the U.K. GDPR, and the Swiss Federal Act on Data Protection may apply to your personal information.
15.1 Legal Bases for Processing
We process your personal information on the following legal bases: performance of a contract with you; compliance with our legal obligations; our legitimate interests (including operating our business, preventing fraud, securing our systems, and providing and improving our services); and your consent (which you may withdraw at any time).
15.2 Your Rights
Subject to applicable law, you may have the right to access, rectify, erase, restrict, or object to our processing of your personal information; to data portability; to withdraw consent; and to lodge a complaint with your local data-protection authority.
15.3 International Transfers
We are based in the United States, and personal information we collect will be transferred to and processed in the United States and other countries that may have data-protection laws different from those in your country. Where required, we use appropriate safeguards (such as the European Commission’s Standard Contractual Clauses and the U.K. International Data Transfer Addendum) to protect personal information transferred internationally.
16. Children’s Privacy
Our Site and services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16. If you believe a child has provided personal information to us, please contact us at pod@flycraft.com and we will take appropriate steps to delete the information.
17. Third-Party Sites and Services
Our Site may contain links to third-party websites and services that are not operated by the Craft Companies. We are not responsible for the privacy practices of those third parties, and this Policy does not apply to information collected by them. We encourage you to review the privacy policies of any third-party site you visit.
18. Changes to This Policy
We may update this Policy from time to time. When we make material changes, we will notify you by posting the updated Policy on the Site, by email, or by other means as required by law. The “Effective Date” at the top of this Policy indicates when it was last revised.
19. Contact Us
You can contact us about this Privacy Policy by writing or emailing us at the address below:
Craft Financials, Inc.
Attn: Privacy Officer
c/o Pod Securities, LLC
14200 NW 42nd Avenue
Opa-locka, Florida 33054
Email: pod@flycraft.com
Phone: (310) 848-3636
Website: www.flycraft.com
THIS PRIVACY POLICY IS PROVIDED TO YOU FOR INFORMATIONAL PURPOSES ONLY. YOU DO NOT NEED TO CALL OR TAKE ANY ACTION IN RESPONSE TO THIS POLICY. WE RECOMMEND THAT YOU READ AND RETAIN THIS POLICY FOR YOUR PERSONAL RECORDS.