May 13, 2024


The Vibes Company Inc. and its subsidiary, Ocho Investment Advisors LLC (collectively “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website (our “Website”), related websites, mobile software applications, and other offerings, including the services provided by our subsidiary, Ocho Investment Advisors, LLC (collectively, the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect:

– On this Website;

– In email, text, and other electronic messages between you and this Website;

– Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website;

– When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy; and

– From our subsidiary, Ocho Investment Advisors LLC, in connection with its provision of investment advisory services.

Relationship Between The Vibes Company Inc. and Ocho Investment Advisors LLC

Ocho Investment Advisors LLC is a subsidiary of The Vibes Company Inc. (“Vibes”). Ocho Investment Advisors, LLC is a registered investment advisor that provides internet-based advisory services for tax-advantaged and taxable accounts, including Solo 401(k) and IRAs. Clients may have a separate relationship with Ocho Investment Advisors, LLC for the management of their accounts. The Privacy Notice for Ocho Investment Advisors can be obtained here. 

Children Under the Age of 18

Our Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Services. We do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services, including information:

– By which you may be personally identified, such as name, postal address, email address, telephone number, social security number (“Personal Information”);

– That is about you but individually does not identify you, such as tracking and usage information about your location, demographics, and use of the Services (“Non-Personal Information”);

– About your internet connection, the equipment you use to access our Services, and usage details.

We collect this information:

– Directly from you when you provide it to us;

– Automatically as you navigate through the site (information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies);

– From our subsidiary, Ocho Investment Advisors LLC, in connection with its provision of investment advisory services.

The types of personal information collected may vary depending on the specific type of tax-advantaged account you have and whether you utilize the investment advisory services provided by Ocho Investment Advisors, LLC.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

– To present our Services and their contents to you;

– To provide you with information, products, or services that you request from us;

– To fulfill any other purpose for which you provide it;

– To provide you with notices about your account, including expiration and renewal notices;

– To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

– To notify you about changes to our Services or any products or services we offer or provide through them;

– To allow you to participate in interactive features on our Services;

– To provide the investment advisory services offered by Ocho Investment Advisors, LLC;

– In any other way we may describe when you provide the information; and

– For any other purpose with your consent.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

– To our subsidiaries and affiliates, including Ocho Investment Advisors, LLC;

– To contractors, service providers, and other third parties we use to support our business;

– To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of The Vibes Company Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by The Vibes Company Inc. about our Services’ users is among the assets transferred;

– To fulfill the purpose for which you provide it;

– For any other purpose disclosed by us when you provide the information; and

– With your consent.

We may also disclose your personal information:

– To comply with any court order, law, or legal process, including to respond to any government or regulatory request;

– To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and

– If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of The Vibes Company Inc., our customers, or others.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. These measures include industry-standard security protocols, encryption of sensitive data, and regular security audits.

However, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk.

Your Rights and Choices

You have certain rights regarding your personal information, which may vary depending on your jurisdiction. To the extent provided by applicable law, you may:

1. Request access to the personal information we maintain about you and request details about how we process it;

2. Request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes;

3. Request that we update or correct inaccuracies in your personal information;

4. Request that we block or delete your personal information from our database;

5. Opt out of sharing your personal information with unaffiliated or non-agent third parties for promotional purposes. 

6. Opt out of marketing communications from Carry

To exercise any of these rights or to make any other inquiries about this privacy policy, please contact us using the information provided in the Contact Information section below. We may take steps to verify your identity before granting you access to your personal information or fulfilling your request to protect your privacy and maintain security.

Please note that your rights may be subject to certain limitations and exceptions under applicable law. In some cases, we may charge a fee to fulfill your request, as permitted by law. If you are a California resident, you have the right under California Civil Code Section 1798.83 to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us or write to us at the address provided in the Contact Information section.

We will respond to your request within a reasonable timeframe and in accordance with applicable law. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Services and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: