Privacy Policy

Last updated: 06.12.2026

This Privacy Policy explains how Investment Management Associates, Inc. (“IMA,” “we,” “us,” or “our”) collects, uses, and shares information when you visit imausa.com (the “Site”), contact us, request information, subscribe to our newsletter, apply for a job, or otherwise interact with us online.

This policy covers the imausa.com website only. If you are or become an IMA advisory client, IMA’s separate Privacy Notice for Clients — delivered under the Gramm-Leach-Bliley Act (GLBA) and Regulation S-P — governs how we handle your nonpublic personal financial information (NPI). That notice is available at [link to GLBA Privacy Notice] and prevails over this policy for client-specific information. If anything in this policy conflicts with the GLBA Privacy Notice for client NPI, the GLBA Privacy Notice controls.

1. Who we are

IMA is a Denver-based investment adviser registered with the U.S. Securities and Exchange Commission. We provide individual portfolio management services to clients across the United States.

Contact: Investment Management Associates, Inc. 5690 DTC Blvd, Suite 140W Greenwood Village, CO 80111-3232 Phone: 303-796-8333 Email:

Privacy questions can be directed to our Chief Compliance Officer at the address above.

2. Information we collect

2.1 Information you give us directly

  • Contact form: your name, email address, phone number, and the content of your message when you submit the contact form on the homepage or at /contact/.
  • Request Performance form: your name, email address, and any other information you provide when you request IMA’s historical performance materials at /request-our-performance/. We may follow up with you to verify your status as an accredited investor or qualified prospective client before sending materials.
  • Download Brochure form: your name and email address when you request our brochure at /download-brochure/.
  • Newsletter subscription: your email address, and optionally your name, when you sign up for Vitaliy Katsenelson’s articles. Subscriptions are processed and managed by Mailchimp (Intuit Inc.).
  • Careers: if you apply for a position with IMA, we collect your name, contact information, resume or CV, work history, education, references, and any other information you choose to share. We use this information only to evaluate your application and, if you are hired, to onboard you as an employee.
  • Correspondence: if you email or call us, we receive whatever information you choose to share.

Information you submit through any of these forms may be used to qualify you as a prospective client and to contact you about IMA’s investment services. If you become an IMA client, that information transitions to coverage under our GLBA Privacy Notice for Clients.

2.2 Information collected automatically

When you visit the Site, we and our service providers may automatically collect:

  • Device and browser data: IP address, browser type, operating system, device type, screen size, referring URL, language preference.
  • Usage data: pages visited, time on page, clicks, scroll depth, downloads, search terms, dates and times of access. This is collected primarily through Google Analytics (Google LLC).
  • Cookies and similar technologies: see Section 6 below.

We do not use the Meta Pixel or any other advertising or behavioral-targeting tracker on imausa.com.

2.3 Information from third parties

  • Mailchimp engagement data: Mailchimp tells us whether and when newsletter emails are delivered, opened, and clicked, and whether they bounce or are marked as spam.
  • Public sources and referrals: we may receive information about prospective clients from professional referrals, your own publicly available materials (such as LinkedIn), or our existing clients who recommend you.

3. How we use your information

We use the information described above to:

  • Respond to your inquiries, contact requests, and performance/brochure requests.
  • Send you the newsletter and other communications you have requested.
  • Evaluate your suitability for our investment services and contact you about becoming a client.
  • Evaluate job applications and conduct hiring processes.
  • Operate, maintain, and improve the Site.
  • Understand which content prospective clients find most useful.
  • Comply with our legal and regulatory obligations as an SEC-registered investment adviser, including recordkeeping requirements under the Investment Advisers Act and Regulation S-P.
  • Detect and prevent security incidents and fraud.

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising. We do not use your information for automated decisions that produce legal or similarly significant effects.

4. Legal bases (for visitors in the EEA, UK, and Switzerland)

If you are in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR / UK GDPR:

  • Consent, for newsletter subscriptions and for non-essential cookies, including Google Analytics. If you visit the Site from the European Economic Area, the United Kingdom, or Switzerland, we obtain this consent through a cookie consent banner displayed on your first visit. Non-essential cookies are not set on your browser until you make a choice in the banner.
  • Legitimate interests, for operating and securing the Site, evaluating prospective client inquiries, answering your questions, and similar core purposes. We have assessed that these interests are not overridden by your rights and freedoms.
  • Performance of a contract or pre-contractual measures, where we are responding to a request you have made or processing your information in preparation for entering into a service agreement.
  • Legal obligation, where we are required to retain certain records under U.S. securities laws or other applicable law.

You can withdraw consent at any time without affecting the lawfulness of processing before the withdrawal. To withdraw cookie consent or change your choices, use the “Privacy Choices“ link in the Site footer.

For transfers of personal information from the EEA, UK, or Switzerland to the United States, we rely on Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable), and on the EU-U.S. Data Privacy Framework and its UK and Swiss extensions where our service providers are certified.

5. How we share information

We share information only as described below. We do not rent or sell personal information.

Service providers that operate the Site and our business on our behalf, including:

  • Mailchimp (Intuit Inc.) — newsletter delivery and email engagement analytics
  • Google Analytics (Google LLC) — Site analytics
  • Orion Advisor Solutions — client portal, portfolio reporting, and related advisory technology (Orion is accessed at login.orionadvisor.com and operates under its own privacy practices)
  • WordPress hosting and infrastructure providers
  • Akismet Anti-spam filtering for forms

Each of these providers is permitted to use the data only to deliver services to us.

Custodians and counterparties: if you become an IMA client, certain information may be shared with the qualified custodian holding your assets and other counterparties as necessary to manage your account. This sharing is described more fully in our GLBA Privacy Notice for Clients.

Affiliated content: information collected through the Site may be shared with Vitaliy Katsenelson’s personal websites and projects (investor.fm and myfavoriteclassical.com) to the extent you have subscribed to content distributed across these properties.

Regulators and legal process: we may disclose information to regulators (including the SEC, FINRA, state securities regulators, or self-regulatory organizations) and other authorities when required by law, in response to a lawful request, in connection with an examination or investigation, or to protect our rights, your safety, or the safety of others.

Business transfers: if we are involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to standard confidentiality protections.

6. Cookies and tracking technologies

The Site uses cookies and similar technologies, including:

  • Strictly necessary cookies that enable core functionality (e.g., maintaining your session, recording your cookie consent choices, protecting forms from spam).
  • Analytics cookies set by Google Analytics to help us understand how visitors use the Site in aggregate.
  • Functionality cookies set by embedded third-party content, including any video embeds or social media widgets. These third parties set their own cookies that we do not control.

How we ask for your consent and how you can change it

If you visit the Site from the European Economic Area, the United Kingdom, or Switzerland, we display a cookie consent banner on your first visit asking for your permission to set non-essential cookies (analytics). Your location is determined automatically based on your IP address. Non-essential cookies are not loaded until you make a choice in the banner. Strictly necessary cookies are always set.

If you visit the Site from anywhere else, including all locations in the United States, the banner is not displayed and non-essential cookies may be set when you visit the Site, in accordance with applicable law. You can manage your cookie preferences at any time by clicking the “Privacy Choices“ link in the Site footer. The link is available to all visitors regardless of location.

If you are traveling or using a VPN, the banner’s behavior follows your detected location rather than your residence. You can always exercise the rights described in Section 9 regardless of where you are when you visit the Site.

Global Privacy Control

We honor the Global Privacy Control (GPC) browser signal as an opt-out under California law and similar US state laws. When we detect a GPC signal, we treat it as a request to opt out of any “sale” or “sharing” of personal information for your browser and device. We do not sell or share personal information for cross-context behavioral advertising in any case, but we honor GPC as an additional opt-out from non-essential analytics.

7. Email newsletter and communications

If you subscribe to the newsletter, we will send you regular emails containing Vitaliy Katsenelson’s articles and related content via Mailchimp. We may include information about IMA’s services or Vitaliy’s books and events.

Every email contains an unsubscribe link. You can also unsubscribe at any time by emailing us at . After you unsubscribe we keep a suppression record so we do not accidentally re-subscribe you.

8. Data retention

We keep personal information only as long as needed for the purposes described above, subject to longer retention required by law:

  • Prospective-client inquiries, performance requests, and brochure requests: typically retained for up to 5 years after our last interaction with you, to comply with SEC books-and-records rules applicable to IMA’s marketing communications.
  • Client records: if you become an IMA client, your records are retained for at least 5 years after the end of our advisory relationship, as required by SEC rules and longer where required by applicable law.
  • Newsletter subscribers: for as long as you remain subscribed, plus a suppression record after you unsubscribe.
  • Job applications: typically retained for up to 2 years after the position is filled or you withdraw, unless a longer period is required by law. If we keep your information to consider you for future roles, we will do so only with your permission.
  • Contact-form submissions: typically up to 3 years after our last interaction.
  • Google Analytics data: retained for 14 months in identifiable form (configurable in our Analytics settings).

Records connected to IMA’s regulatory obligations as a registered investment adviser are retained for the periods required by the Investment Advisers Act and Regulation S-P (generally at least 5 years and in some cases longer).

9. Your choices and rights

General rights

Depending on where you live, you may have some or all of the following rights:

  • Access the personal information we hold about you.
  • Correct information that is inaccurate or incomplete.
  • Delete your personal information (subject to limits — see below).
  • Restrict or object to certain processing, including direct marketing.
  • Data portability, for information you have provided to us.
  • Withdraw consent at any time.
  • Lodge a complaint with a data protection authority. In the EEA, that is your local supervisory authority; in the UK, the Information Commissioner’s Office (ICO).

Important limits on deletion and restriction. As an SEC-registered investment adviser, IMA is required by law to retain certain records for specified periods. We cannot delete information that we are required to retain — including client records, marketing communications subject to SEC books-and-records rules, and information needed to defend or assert legal claims. Where this applies, we will tell you what we can and cannot delete.

To exercise any of these rights, email us at . We may need to verify your identity before responding. We will respond within the timeframes required by applicable law (typically 30 days under GDPR/UK GDPR, 45 days under CCPA, extendable where permitted). You may authorize an agent to make a request on your behalf.

California residents (CCPA/CPRA)

In addition to the rights listed above, California residents have the right to:

  • Know the categories and specific pieces of personal information we collect, the sources, the business purposes, and the categories of third parties with whom we share it.
  • Opt out of “sale” and “sharing” of personal information. We do not sell or share personal information for cross-context behavioral advertising on this Site, so no opt-out is required. We honor Global Privacy Control as described in Section 6.
  • Limit the use of sensitive personal information. We do not use or disclose sensitive personal information for purposes that require an opt-out right under California law.
  • Non-discrimination for exercising these rights.

Note: financial information collected from California consumers in connection with a financial product or service is generally exempt from the CCPA under the GLBA/FIPA exemption and is instead governed by our GLBA Privacy Notice for Clients.

EEA, UK, and Swiss residents

You have the additional right to withdraw consent for any processing based on consent, and the right to object to processing based on legitimate interests, including profiling for direct marketing.

10. International transfers

We are based in the United States. If you access the Site from outside the United States — including from the EEA, UK, Switzerland, or California — your information will be transferred to, processed in, and stored in the United States and other countries where our service providers operate. For transfers from the EEA, UK, and Switzerland, we rely on EU Standard Contractual Clauses, the UK International Data Transfer Addendum, and the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) where applicable.

IMA is registered with the SEC and is generally not authorized to provide advisory services to residents of jurisdictions outside the United States. Submission of information through this Site does not establish an advisory relationship.

11. Security

IMA maintains a written information security program designed to protect personal information from loss, misuse, and unauthorized access, in accordance with Regulation S-P and other applicable law. Our safeguards include access controls, encryption in transit, employee training, vendor due diligence, and an incident response plan with breach notification procedures.

No internet transmission or electronic storage is ever fully secure, however, so we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you and applicable regulators as required by law.

12. Children’s privacy

The Site is intended for adults. We do not knowingly collect personal information from children under 16. If you believe a child has provided us with personal information, please contact us and we will delete it.

13. Third-party links and content

The Site links to external sites, including:

  • investor.fm and myfavoriteclassical.com — Vitaliy Katsenelson’s personal websites
  • soulinthegame.net — Vitaliy Katsenelson’s book site
  • conference.investor.fm — The Intellectual Investor Conference
  • login.orionadvisor.com — Orion Advisor client portal
  • Media outlets such as Barron’s, Financial Times, CNBC, Wall Street Journal, Institutional Investor, Fortune, and MarketWatch
  • Social media platforms

We are not responsible for the privacy practices of those sites. Please review their policies separately. Each of Vitaliy’s personal sites has its own privacy policy.

14. Investment-related disclosures

Content on the Site is for informational and educational purposes only. Visiting the Site, requesting our performance materials or brochure, subscribing to the newsletter, or submitting a contact form does not create an advisory, fiduciary, or client relationship with IMA. Personalized investment advice is provided only under a separate written agreement with IMA.

For information about IMA’s services, fees, conflicts of interest, and disciplinary history, see our Form ADV Part 2A and 2B and Form CRS (Client Relationship Summary), available at /faq/#docs and on the SEC’s Investment Adviser Public Disclosure website at adviserinfo.sec.gov.

Testimonials displayed on the Site are governed by SEC Rule 206(4)-1 (the Marketing Rule), including required disclosures about compensation.

15. Changes to this policy

We may update this policy from time to time. When we do, we will revise the “Last updated” date above. If changes are material, we will provide a more prominent notice — for example, by email to newsletter subscribers, a banner on the Site, or for clients, a separate notification under our GLBA Privacy Notice procedures.

16. How to contact us

Questions, requests, or complaints about this policy or our handling of your personal information:

Investment Management Associates, Inc. Attn: Chief Compliance Officer / Privacy 5690 DTC Blvd, Suite 140W Greenwood Village, CO 80111-3232 Phone: 303-796-8333 Email:

Investment Management Associates, Inc. - A Premier Value Investing Firm