Last updated: 05.28.2026.
This Privacy Policy explains how Vitaliy Katsenelson and Investment Management Associates, Inc. (“IMA,” “we,” “us,” or “our”) collect, use, and share information when you visit investor.fm (the “Site”), subscribe to The Intellectual Investor newsletter, listen to the podcast, comment on articles, or otherwise interact with us online.
This policy covers the investor.fm 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 and Regulation S-P) governs how we handle your nonpublic personal financial information. That notice is available here and prevails over this policy for client-specific information.
1. Who we are
The Site is operated by Investment Management Associates, Inc., a Colorado-based SEC-registered investment adviser. Vitaliy Katsenelson is the author of the content published on the Site.
Contact: Investment Management Associates, Inc. 5690 DTC Blvd, Suite 140W, Greenwood Village CO 80111-3232 Email:
2. Information we collect
2.1 Information you give us directly
- Newsletter subscription: your email address, and optionally your name, when you sign up for The Intellectual Investor newsletter. Subscriptions are processed and managed by Mailchimp (Intuit Inc.).
- Comments: your name, email address, website (optional), and the content of any comment you submit on an article. Comments also automatically capture your IP address and browser user-agent string, which is standard WordPress behavior used to fight spam.
- Contact forms: any information you submit through the contact form, including your name, email address, phone number, and the content of your message. Contact-form submissions are routed to IMA at imausa.com.
- Event and conference registrations: information you submit through registration forms (such as the Intellectual Investor Breakfast and The Intellectual Investor Conference), which are processed by third-party form providers including monday.com.
- Correspondence: if you email us or message us on social media, we receive whatever information you choose to share.
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 used on the Site, dates and times of access. This is collected primarily through Google Analytics (Google LLC).
- Advertising and conversion data: we use the Meta Pixel (Meta Platforms, Inc.) to measure how visitors interact with the Site, including page views, button clicks, form submissions, and other events. The Meta Pixel allows Meta to associate your activity on the Site with your Facebook or Instagram account if you are logged into Meta services. This information is used by Meta to deliver advertising, build audiences (including “Custom Audiences” and “Lookalike Audiences”), and measure ad performance. Meta acts as a separate controller for some of this processing. For more information, see Meta’s Privacy Policy at https://www.facebook.com/privacy/policy.
- Cookies and similar technologies: see Section 6 below.
- Podcast listening data: when you stream or download podcast episodes hosted by Libsyn, Libsyn logs IP address, user agent, approximate geographic location, and episode/playback information for analytics purposes.
2.3 Information from third parties
- Social media: if you engage with our content on Facebook, X (Twitter), LinkedIn, YouTube, Instagram, or TikTok, those platforms may share information with us in accordance with their own settings and policies.
- 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.
- Meta advertising data: Meta may share aggregated audience insights and ad performance data with us.
- Affiliate networks: links to Amazon and other retailers on the Site are affiliate links. When you click them, the destination retailer’s network may report back whether a purchase was made attributable to our referral. We do not receive your name, payment details, or the items you bought.
3. How we use your information
We use the information described above to:
- Send you the newsletter and other communications you have requested.
- Operate, maintain, and improve the Site, the podcast, and our content.
- Respond to your questions, comments, and contact requests.
- Moderate comments and prevent spam, abuse, and fraud.
- Understand which articles, episodes, and topics our audience finds most valuable.
- Measure and improve the performance of our marketing, including advertising on Meta platforms.
- Build audiences for advertising on Meta platforms, including audiences based on your interaction with the Site.
- Process registrations for events and conferences.
- Comply with legal obligations, including recordkeeping requirements applicable to investment advisers.
- Detect and prevent security incidents.
We do not sell your personal information for money. We do “share” information for cross-context behavioral advertising within the meaning of California law, through the Meta Pixel and similar tools. See Section 9 for how to opt out.
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 and trackers, including Google Analytics and the Meta Pixel. If you visit the Site from the European Economic Area, the United Kingdom, or California, we obtain this consent through a cookie consent banner displayed on your first visit. Non-essential cookies and trackers are not set on your browser until you make a choice in the banner.
- Legitimate interests, for operating and securing the Site, answering your inquiries, and similar core purposes. We have assessed that these interests are not overridden by your rights and freedoms.
- Performance of a contract, where we are responding to a request you have made.
- Legal obligation, where we are required to retain certain records.
You can withdraw consent at any time without affecting the lawfulness of processing before the withdrawal. To withdraw consent or change your choices, visit the Your Privacy Choices page, available from the link in the Site footer.
For transfers of personal information from the EEA, UK, or Switzerland to the United States and other countries, 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 for money.
Service providers that operate the Site on our behalf, including:
- Mailchimp (Intuit Inc.) — newsletter delivery and email engagement analytics
- Google Analytics (Google LLC) — Site analytics
- Meta Platforms, Inc. — advertising measurement, retargeting, and audience building via the Meta Pixel
- Libsyn — podcast hosting and delivery
- monday.com — event and conference registration forms
- Akismet / Automattic — anti-spam filtering for comments
- Hosting and infrastructure providers
Each of these providers is permitted to use the data only to deliver services to us, except for Meta, which acts as an independent controller for some advertising-related processing as described in Section 2.2.
Affiliated entities: information collected through the Site may be shared with Investment Management Associates, Inc. and Vitaliy Katsenelson personally.
Legal and safety: we may disclose information when we believe in good faith that disclosure is required to comply with a legal obligation, lawful request from authorities, court order, 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., remembering that you have submitted a comment, recording your cookie consent choices).
- Analytics cookies set by Google Analytics to help us understand how visitors use the Site in aggregate.
- Advertising cookies set by the Meta Pixel to measure ad performance, retarget visitors with ads on Facebook and Instagram, and build advertising audiences.
- Functionality cookies set by embedded third-party content, including YouTube video embeds, the Libsyn podcast player, and 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 California, we display a cookie consent banner on your first visit asking for your permission to set non-essential cookies and trackers (analytics and advertising). Your location is determined automatically based on your IP address. Non-essential cookies and trackers 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, the banner is not displayed and non-essential cookies and trackers may be set when you visit the Site, in accordance with applicable law. You can manage your cookie preferences and opt out of non-essential cookies and trackers at any time by visiting the Your Privacy Choices page, accessible from the link in the Site footer. The link to this page 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.
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 of the “sale” and “sharing” of personal information under California law and similar US state laws. When we detect a GPC signal from your browser, we automatically treat it as a request to opt out of cross-context behavioral advertising (including the Meta Pixel) for your browser and device, without you needing to take any further action.
7. Email newsletter and communications
If you subscribe to the newsletter, we will send you regular emails containing articles, podcast announcements, and related content via Mailchimp. We may include information about IMA’s investment 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:
- Newsletter subscribers: for as long as you remain subscribed, plus a suppression record after you unsubscribe.
- Comments: indefinitely, unless you ask us to remove them, so the article discussion remains intact.
- Contact and event-form submissions: typically for up to 3 years after our last interaction with you, unless a longer period is required by law.
- Google Analytics data: retained for 14 months in identifiable form (configurable in our Analytics settings).
- Meta Pixel data: retention is governed by Meta’s own policies.
Records connected to IMA’s regulatory obligations as a registered investment adviser are retained for the periods required by the Investment Advisers Act and SEC rules (generally at least 5 years).
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.
- 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).
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 personal information for money, but we do “share” it for cross-context behavioral advertising through the Meta Pixel. You can opt out by any of the following methods:
- Visiting the Your Privacy Choices page, accessible from the link in the Site footer, and selecting the option to opt out of the sale and sharing of personal information,
- Enabling Global Privacy Control in your browser — we automatically honor this signal as an opt-out, or
- Emailing us at with your request.
- Limit the use of sensitive personal information. We do not use or disclose sensitive personal information for purposes that require an opt-out right.
- Non-discrimination for exercising these rights.
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.
11. Security
We use reasonable administrative, technical, and physical safeguards designed to protect personal information from loss, misuse, and unauthorized access. No internet transmission or electronic storage is ever fully secure, however, so we cannot guarantee absolute security.
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 imausa.com, soulinthegame.net, conference.investor.fm, myfavoriteclassical.com, Amazon, Libsyn, social media platforms, and others. We are not responsible for the privacy practices of those sites. Please review their policies separately.
14. Investment-related disclosures
Content on the Site is for informational and educational purposes only. Reading the Site, subscribing to the newsletter, or commenting on articles does not create an advisory, fiduciary, or client relationship with IMA or Vitaliy Katsenelson. Personalized investment advice is provided only under a separate written agreement with IMA. See IMA’s Form ADV, Form CRS, and other regulatory filings at imausa.com for information about its services and conflicts of interest.
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 or a banner on the Site.
16. How to contact us
Questions, requests, or complaints about this policy or our handling of your personal information:
Investment Management Associates, Inc. Attn: Privacy 5690 DTC Blvd, Suite 140W, Greenwood Village CO 80111-3232 Email:
