A. Types of Personal Information Subject to California Privacy Law
In accordance with California law, we may have collected the following categories of Personal Information within the preceding 12 months:
- Protected classification characteristics under California or federal law. The Firm does not require you provide protected classification characteristics. However, please carefully consider the information contained within new account applications and advisory agreements to ensure that you are not providing any protected classification characteristics that are not necessary for your engagement with us as your advisor. Dependent upon the scope of services, a financial custodian may require certain information from you in order to perform the services (the most common being birth date). The Firm may collect this information on behalf of the custodian. Protected classification characteristics include your age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, genetic information (including familial genetic information), and veteran or military status. The Firm and the third-party custodian may use this information to perform wealth management and financial advisory services tailored to meet your specific financial and life goals.
- Internet or other electronic network activity information, including cookie data and other information on your usage of our website. We use this information to provide targeted advertising based upon your interest in the Firm.
- Professional or employment-related information including any information provided in a resume/CV or job seeker profile. We use this information for the limited purpose of employment screening and hiring practices.
The Firm does not sell data or share information to a third party for cross-context behavioral advertising. We may share each of these categories of Personal Information with our service providers to the extent necessary to perform administrative services for the Firm, if a client or client representative directs us to do so, or if we are compelled by law to disclose personal information, such as to government entities, credit bureaus or in response to subpoenas.
B. Your California Privacy Rights
If you are a resident of State of California, you have the following rights:
- Right to Access Your Personal Information: You have the right to request that we disclose the Personal Information that the Firm collected about you in the 12 months before your request.
- Right to Delete Your Personal Information: You have the right to request that we delete the Personal Information that the Firm collected from you.
- Right to Opt-Out of the Sale of Your Personal Information: You have a right to opt-out of the “Sale” of your Personal Information.
- Right to Opt-Out of the Sharing of Your Personal Information: You have a right to opt-out of the “Sharing” of your Personal Information for cross-contextual behavior advertising.
- Right to Non-Discrimination: You have the right not to be discriminated against on account of exercising the rights granted to you under the CCPA.
C. Exercising Your California Privacy Rights
Contact Information: To exercise the rights described above, please submit a verifiable request to the Firm by either:
Right to Access / Delete:
The Firm may not be able to delete your personal information if such information pertains to your employment or is required to be retained by law. Upon receipt of your deletion request, the Firm will review and confirm if it is a verifiable request, and if so, the Firm will delete (and direct our third-party suppliers to delete) your data. The Firm may deny a deletion request, in whole or in part, if retaining the information or a portion of the information is required for the Firm or our third-party suppliers and contractors under an exemption called out in the CCPA or CPRA, including (if applicable):
a. Information collected pursuant to the California Financial Information Policy as well as the Graham Leach Bliley Act.
b. Information required to meet ongoing commercial obligation on your behalf;
c. To comply with applicable laws, subpoenas, legal proceeding, or audit; or
d. In order to improve our internal business practices, such as updating our website, improving cybersecurity, and any other solely internal business purpose reasonably anticipated within the context of our business relationship.
The Firm will endeavor to respond to any verified consumer request within 45 days. If the Firm is unable to respond, the Firm will provide written notice to extend the response time by up to 90 additional days where necessary, taking into account the complexity and number of the requests. The Firm shall inform the consumer of any such extension within 45 days of receipt of the request, together with the reasons for the delay. If the Firm is unable to complete your request, the Firm will inform you, without delay and at the latest within the time period allotted above, of the reasons for not taking action and any rights You have to appeal the decision to the Firm.
Right to Opt Out of the Sale or Sharing of Information for Cross-Contextual Behavior Advertising: The Firm does not disclose your personal information to third parties for the third parties’ direct marketing purposes unless you affirmatively agree to it. If this policy were to change, you can opt-out of such disclosure by contacting the Firm using the contact information above, or using the following: OPT OUT LINK
Right of Right Non-Discrimination following Exercise of Rights: The Firm does not discriminate against any consumer, client, advisor, or employee after exercising any of the rights listed above. The Firm does not provide financial incentives for sharing data.
Verification of Identity: Only you, or someone appointed by you and registered with the California Secretary of State, may request deletion of your data. The deletion request must provide sufficient detail to enable the Firm to identify you, such as providing your identifiable information to cross-reference with any submitted data, and describe your deletion request with sufficient detail that allows us to understand that you desire to exercise your rights under the CCPA and the CPRA. We do not require you to create an account and will only use any data submitted to us for a deletion request for that specific request. You may only submit two requests every twelve months, or as otherwise set forth in the CCPA and the CPRA.
Using an Authorized Agent: You have the right to designate someone else to act on your behalf as your authorized agent to exercise some of your privacy rights. An authorized agent may need to provide documentation supporting the agent’s authority to make this request on your behalf, such as a signed authorization form. The Firm may also require you to verify your identity directly with the Firm and confirm the request before the Firm will process any request.
D. Contact Information: The Firm welcomes any questions or comments about this notice, or the Firms’ privacy policies. Please direct any questions or comments to:
Last published date: March 22, 2023