Effective Date: January 2025
Last Updated: Nov. 2025

Investment Counsel Exchange, LLC (“ICE,” “we,” “us,” or “our”) is committed to protecting your privacy and providing transparency regarding how we collect, use, and safeguard your information. ICE is a Florida-based educational and consulting company. ICE is not a law firm and does not provide legal, tax, or investment advice.

This Privacy Policy applies to information collected through our website, communications, services, and related platforms.

ICE does not request, store, or collect the following information:

• Social Security Numbers
   
• Driver’s license or state ID numbers
   
• Personal health information (PHI)
   
• Biometric identifiers
   
• Sensitive personal information (race, religion, political affiliation, or sexual orientation)
   
• Bank account or wiring information unless voluntarily provided for a transaction coordinated with a Qualified Intermediary
   

We believe in collecting only what is necessary to provide our services safely and effectively.

If you submit forms, request information, or contact us, we may collect:

• Name
   
• Email address
   
• Phone number
   
• Business or professional affiliation
   
• Transaction-related information you voluntarily provide (for QI coordination)
   

ICE does not collect personal financial information unless you intentionally and voluntarily provide it for coordination with an independent Qualified Intermediary (QI).

Automatically collected data may include:

• IP address
   
• Device type, browser type, and operating system
   
• Pages visited, time spent, and site interactions
   
• Cookies, analytics, and tracking technologies
   
• General geographic location (city/region—not precise GPS)
   

This information helps us improve website performance and security.

We use your information to:

• Provide and improve our educational and consulting services
   
• Coordinate communications with independent Qualified Intermediaries
   
• Respond to questions, requests, or support inquiries
   
• Send updates or marketing (you may opt out anytime)
   
• Maintain website functionality and security
   
• Comply with legal obligations
   

ICE does not use your information for automated decision-making or profiling.

We do not sell, trade, or rent your personal information.

We may share information only with:

Such as:

• Website hosting (GoDaddy)
   
• Email and communication platforms
   
• Analytics providers
   
• Independent Qualified Intermediaries (only with your direction or consent)
   

These providers must use your information solely to perform their contracted services.

We may disclose information if required by:

• Court order
   
• Subpoena
   
• Law enforcement request
   
• Applicable regulations
   

ICE complies with state and federal privacy and data-retention laws.

ICE uses cookies and similar technologies to:

• Improve site usability
   
• Track performance
   
• Enhance security
   

You can disable cookies in your browser settings, though some features may not function properly.

We use industry-standard measures including:

• SSL encryption
   
• Secure hosting through GoDaddy
   
• Access controls and authentication
   
• Limited data retention
   

While no system can guarantee perfect security, we take reasonable steps to safeguard your information.

Depending on your jurisdiction, you may have the right to:

• Access the personal information we store
   
• Request corrections to inaccurate data
   
• Request deletion of certain data
   
• Opt out of marketing communications
   
• Request limitations on certain processing
   
• Request a copy of the data you provided
   

To make any privacy request, please contact:
📩 Robert@Genders1031.com

We will respond within the time required by applicable law.

Our website may contain links to external websites, including qualified intermediary partners or educational resources.
Those sites are governed by their own privacy policies.

Our services are not intended for individuals under the age of 18.
We do not knowingly collect information from minors.

We may update this Privacy Policy periodically to reflect:

• Legal changes
   
• Operational changes
   
• New services or technologies
   

The “Last Updated” date will always indicate the most recent revision.

Investment Counsel Exchange, LLC
Website: www.InvestmentCounselExchange.com
Email: Robert@Genders1031.com
Phone: (813) 420-3750