This Privacy Policy applies to information collected through our website and other non-client interactions. For information regarding how we collect, use, and share personal financial information of advisory clients, please review our Regulation S-P Privacy Notice. This Privacy Policy is intended to comply with applicable privacy laws in jurisdictions where we conduct business and does not constitute an agreement or representation that we comply with the privacy laws of jurisdictions in which we do not operate or target residents.

Brickley Wealth Management (“BWM”) and its affiliates want you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes our practices in connection with information that we collect online and offline:

• through our websites (“Websites”);
• through the software applications made available by us for use on or through computers and mobile devices (“Apps”);
• through social media properties (“Our Social Media”) from which you are accessing this Privacy Policy;
• through HTML-formatted email messages that we send to you that link to this Privacy Policy (“Emails”);
• through any other offline business interactions, you may have with us (“Offline Interactions”) and
• through services we provide to our individual, corporate, and institutional clients (“Client Services”);  (client financial information is governed by the Reg S-P Privacy Notice, not this policy)

Collectively, we refer to the Websites, the Apps, Our Social Media, Emails, Client Services and Offline Interactions as the “Services.”

COLLECTION OF PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including but not limited to:

• Name;
• Postal address (including personal, business, billing, and shipping addresses);
• Telephone number;
• Email address (personal and business); and
• Job title and employer;

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services
  
  • We collect Personal Information through the Services, for example, when you sign up for a newsletter, request Services, register for a seminar, use Services that can be accessed only by authenticated users who have logged in, participate in a contractual arrangement for Client Services, provide information in conjunction with our Client Services, or when you interact with us at an event, call our reception desk or otherwise visit one of our offices.

• From Other Sources
  
  • We receive your Personal Information from other sources, for example:
    
    • publicly available databases;
    • joint marketing partners and event sponsors when they share the information with us;
    • partner Client Services organizations (such as nonprofits);
    • entities to which we provide Client Services, which may include your employer; and
    • social media platforms.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

USE OF PERSONAL INFORMATION

We and our service providers use Personal Information for legitimate business purposes, including:

• Providing the functionality of the Services and fulfilling your requests.
  
  • To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related client service.
  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise (e.g., when you send us questions, suggestions, compliments, or complaints, or when you request other information about our Services).
  • To send administrative information to you, such as information regarding the Services and changes to our terms, conditions, and policies.
  • To allow you to send Services-related content to another person through the Services if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with our newsletter and/or other marketing materials and facilitating social sharing
  
  • To send you our newsletters, publications, legal updates, and mailings related to our seminars or events that we think may be of interest to you.
  • To fulfill your event registration requests and provide services, including the provision of seminars and other events.
  • To send you information about our services and other news about our firm.

We will engage in this activity with your consent or where we have a legitimate interest.

• Aggregating and/or anonymizing Personal Information.
  
  • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.

• Accomplishing our business purposes.
  
  • For data analysis, for example, to improve the efficiency of our Services.
  • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements.
  • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
  • To meet our legal and regulatory obligations.
  • For enhancing, improving, or modifying our current products and services.
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

• Providing Client Services.
  
  • To validate authorized signatories when concluding agreements and transactions.
  • To contact individuals (including employees of institutional clients) in connection with providing Client Services.
  • To respond to inquiries and fulfill requests from our clients, administer their file(s), provide legal services, and manage our relationships.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

DISCLOSURE OF PERSONAL INFORMATION

We disclose Personal Information:

• To our affiliates for the purposes described in this Privacy Policy.
  
  • You may inquire about our affiliated entity, Brickley & Company CPA, Inc., by contacting our office. Subject to applicable local requirements, information may be  shared to facilitate accounting and related services provided by Brickley & Company CPA, Inc., and for all the purposes outlined in this Privacy Policy.
  • Brickley Wealth Management is the party responsible for the management of the jointly-used Personal Information.

• To our third-party service providers, to facilitate services they provide to us.
  
  • These can include providers of services such as website hosting, Services-related consulting and monitoring, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services related to meeting the services provided to our clients.

• By using the Services, you may elect to disclose Personal Information
  
  • On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, Our Social Media), or through which you are able to send messages through the Services. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.
  
  • This can include laws outside your country of residence.

• To cooperate with public and government authorities.
  
  • For example, when we respond to a request or provide information we believe is important.
  • These can include authorities outside your country of residence.

• To cooperate with law enforcement.
  
  • For example, when we respond to law enforcement requests and orders or provide information we believe is important.

• For other legal reasons.
  
  • To enforce our terms and conditions; and
  • To protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others.

• In connection with a sale or business transaction.
  
  • We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings) Such third parties may include, for example, an acquiring entity and its advisors.

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not relate to an identifiable individual, such as:

• Browser and device information;
• App usage data;
• Information collected through cookies, pixel tags and other technologies;
• Demographic information and other information provided by you that does not reveal your specific identity; and
• Information that has been aggregated in a manner such that it no longer reveals your specific identity.

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

We and our service providers may collect Other Information in a variety of ways, including:

• Through your browser or device:
  
  • Certain information is collected automatically when you visit the website, such as your Internet Protocol (IP) address, browser type and version, operating system, device type, language preferences, and information about how you interact with the website. We use this information to operate, maintain, and improve the website and to support its security and functionality.

• Using cookies
  
  • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences and other traffic data. Some browsers transmit ‘Do-Not-Track’ signals. Because there is not yet a common understanding of how to interpret these signals, we do not currently respond to them. To learn more about how we use cookies, or to opt out of the collection and use of cookies, please see our Cookies Policy by clicking [here].

• Using pixel tags and other similar technologies
  
  • Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
  • Analytics.
    
    • We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s and YouTube’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. To view Google’s and YouTube’s privacy policy, please click here.
    • We use cookies to collect information about how visitors use the Site. We use this information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited.
    • To opt out of being tracked by cookies across all websites visit http://tools.google.com/dlpage/gaoptout.

• IP Address
  
  • Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP address.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

REGULATION S-AM & S-ID COMPLIANCE

Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility information received from an affiliate to make a marketing solicitation unless:

• The potential marketing use of that information has been clearly, conspicuously, and concisely disclosed to the consumer.
• The consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations.
• The consumer has not opted out.

Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity theft. We have developed an ITPP to adequately identify and detect potential red flags to prevent and mitigate identity theft.

SECURITY

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

You have choices regarding marketing-related communications. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the unsubscribe instructions in any such message or by contacting us by email at contact@brickleywealth.com.  We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

If you would like to request to review, correct, update, suppress/delete, or object to or restrict processing of Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company, please feel free to contact us. We will respond to your request consistent with applicable law.  If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under the CCPA and / or the CPRA.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Federal privacy laws give you the right to restrict some sharing of your personal financial information. These laws balance your right to privacy with BWM’s need to provide information for normal business purposes. You have the right to opt out of some information sharing with companies that are: 

• Part of the same corporate group as your financial company (or affiliates).
• Not part of the same corporate group as your financial company (or non-affiliates). 

Choosing to restrict the sharing of our personal financial information will not apply to:

• Information about you to firms that help promote and market the company's own products or products offered under a joint agreement between two financial companies.
• Records of your transactions—such as your loan payments, credit card or debit card purchases, and checking and savings account statements--to firms that provide data processing and mailing services for your company.
• Information about you in response to a court order.

If you opt out, you limit the extent to which BWM can provide your personal financial information to non-affiliates.

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• The length of time we have an ongoing relationship with you as our client and provide you with Client Services;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions or communications for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

If you decide to close your account(s) or become an inactive customer, our Privacy Policy will continue to apply to you which means that we will continue to hold onto your information and share it as described in this notice.

SUCCESSION PLANNING

In the event that the owner(s) of BWM retire, become incapacitated or perish unexpectedly, your information would be disclosed to an unaffiliated third party for the purposes of facilitating a business succession plan. A change in control of ownership of BWM would require your consent, as dictated by your signed agreement with BWM, in order to continue providing services to you.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties.

This includes any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media.

SPECIAL NOTIFICATION ABOUT WEBINARS

Webinars offered as a service to users of the Services (“Webinars”) are hosted by unaffiliated third-party vendors, and not by us.

Our third-party vendors require users to provide Personal Information. This Personal Information includes name and email address. Users seeking continuing legal education credit also may be asked to provide their State Bar number(s). Please note that this Personal Information is collected by our vendors and not by us. We encourage you to read the privacy statements of our vendors, which control how such vendors handle Personal Information provided by you to register for the Webinars.

Additionally, our third-party vendors provide us with Personal Information about users of our Webinars. We use this Personal Information to track attendance, to facilitate future communication with such users, and for other purposes set forth in this Privacy Policy.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Some countries outside of the European Economic Area (the “EEA”) are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these “specified countries” is available here). The UK recognizes the EEA and the specified countries as providing an adequate level of data protection according to UK standards. For transfers from the EEA or the UK to countries not considered adequate by the European Commission or the UK government (as applicable), we have put in place adequate measures, such as standard contractual clauses adopted by the relevant authority, to protect your Personal Information. You may obtain a copy of these measures by clicking here.

SENSITIVE INFORMATION

Other Information is information that does not reveal your specific identity or directly relate to an identifiable individual. Depending on how you interact with us, this may include:

• Browser and device information (such as device type, operating system, and browser type);
• Website usage data (such as pages viewed, time spent on the site, and referring URLs);
• Information collected through cookies, pixel tags, and similar technologies; and
  Aggregated or anonymized information that cannot reasonably be used to identify you.

We collect this information to operate, maintain, and improve our Services, enhance security, and analyze usage trends.

UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

Brickley Wealth Management is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us.

You can reach us at contact@brickleywealth.com or at:

161 W. 25th Ave Suite #204
San Mateo, CA 94403-2283
Attn:  Privacy - Data Compliance

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

AFFILIATES

For purposes of this Privacy Policy, and to obtain a list of entities that are considered to be “affiliates” of Brickley Wealth Management, please contact contact@brickleywealth.com.

ADDITIONAL INFORMATION REGARDING THE EEA AND THE UK

You may lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. A list of EEA data protection authorities is available at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Information regarding the UK data protection authority is available at: https://ico.org.uk/.

ADDITIONAL INFORMATION REGARDING CALIFORNIA

California Consumer Privacy Act

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we collect, use, and disclose about California residents and households.

California Privacy Rights Act

The California Privacy Rights Act (“CPRA”), went into effect on January 1, 2023.  The CPRA replaces and builds on the CCPA by adding additional privacy rights for Californians, under certain circumstances.  The CPRA applied to businesses who meet the following criteria:

• Have annual gross revenue of more than $25,000,000.00 USD;
• Derive 50% or more of its annual revenue from selling or sharing the personal information of California consumers; or
• Annually buy, sell, or share the personal information of 100,000 or more California consumers or households.  

In view of both the CCPA and CPRA, we are providing the following additional details regarding the categories of Personal Information about California residents that we collect, use, and disclose about California residents and households.

Sources of Personal Information

As described above in this Privacy Policy, we collect this Personal Information from you, our affiliates, partner Client Services organizations (such as nonprofits), publicly available databases, social media platforms, and joint marketing partners and event sponsors.

Categories of Personal Information Collected and Disclosed

The following chart details which categories of Personal Information about California residents we plan to collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months:

Use of Personal Information

Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our services, for vendor and employment management, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: provide Client Services; personalize, advertise, and market our services and provide you with content and events of interest; conduct research, analytics, and data analysis; host conferences and events; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; facilitate corporate transactions; and exercise and defend legal claims.

Under the CCPA, if a business sells Personal Information, it must allow California residents to opt out of the sale of their Personal Information. However, we do not “sell” and have not “sold” Personal Information in the preceding 12 months for purposes of the CCPA. For example, and without limiting the foregoing, we do not "sell" the Personal Information of minors under 16 years of age.

Additionally, under the CPRA, we must disclose whether we offer a financial incentive or price or service difference to customers whose Personal Information we collect.  In accordance with the CPRA, we do not offer a financial incentive or price or service difference to customers whose Information we collect.  Individual Rights and Requests

If you are a California resident, you may request that we:

1. Disclose to you the following information covering the 12 months preceding your request:
   
   • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   • The specific pieces of Personal Information we collected about you;
   • The business or commercial purpose for collecting Personal Information about you;
   • The categories of Personal Information about you that we shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information;
   • Whether we offer a financial incentive or price or service difference, and if we do, a description of the incentive or price or service.
2. Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please feel free to contact us in accordance with the address provided in this Privacy Policy.

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. For your protection, we may need to request additional information from you (such as your name, email address, mailing address, and relationship with us) in order to verify your identity and protect against fraudulent requests. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA and CPRA.

Authorized Agents

If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include:

• Proof of your registration with the California Secretary of State to conduct business in California; and/or
• A power of attorney from the California resident pursuant to Probate Code sections 4121-4130.

If you are making a request on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:

• Verify the resident’s own identity directly with us; or
• Directly confirm with us that the resident provided you permission to submit the request.

California “Shine the Light” Disclosures

As noted above in this Privacy Policy, we may disclose Personal Information to affiliates of Brickley Wealth Management, which may use this information for all purposes outlined in this Privacy Policy. If you would like to learn more about this or to make a request to discontinue this type of sharing, please email us at contact@brickleywealth.com or by mail at the following address:

We will provide a list of the categories of Personal Information disclosed to third parties (i.e., our affiliates) for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We will respond to your request in accordance with applicable law and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.

ADDITIONAL INFORMATION REGARDING VIRGINIA

The Virginia Consumer Data Protection Act

The Virginia Consumer Data Protection Act of 2021 (“VCDPA”), went into effect on January 1, 2023, and is designed to give Virginia consumers privacy rights similar to the California rights set forth above.  The VCDPA applies to businesses who meet the following criteria:

• During a calendar year, control or process the personal data of at least 100,000 Virginia consumers; or control or process the personal data of at least 25,000 Virginia consumers and derive more than 50% of gross revenue from the sale of personal data.Control or process the personal data of at least 25,000 consumers and derive 50% or more of its gross revenue from the sale of personal data.  

In view of the VCDPA, and based on the totality of our Privacy Policy, we are compliant with the VCVDPA, if the applicable provisions are relevant.

ADDITIONAL INFORMATION REGARDING COLORADO

The Colorado Privacy Act

The Colorado Privacy Act (SB190) (“CoPA”), will go into effect on July 1, 2023, and is designed to give Colorado residents privacy protections similar to the California rights set forth above.  The CoPA applies to businesses who meet the following criteria:

• Conducts business in Colorado or produces or deliver commercial products or services that are intentionally targeted towards residents of Colorado; and
• Satisfies one of the following thresholds
• During a calendar year, control or process the personal data of at least 100,000 Colorado residents; or 
• Control or process the personal data of at least 25,000 Colorado consumers and derive 50% or more of its gross revenue from the sale of personal data.  

In view of the CoPA, and based on the totality of our Privacy Policy, we are compliant with the CoPA, if the applicable provisions are relevant.

ADDITIONAL INFORMATION OREGON

The Oregon Consumer Privacy Act (“OCPA”) became effective on July 1, 2024, and provides Oregon residents with certain rights regarding their personal data, subject to statutory applicability thresholds and exclusions.

To the extent the Oregon Consumer Privacy Act (“OCPA”) applies to information collected through the Services, Oregon residents may have rights relating to access, correction, deletion, and portability of their personal data, as well as the ability to opt out of the sale of personal data, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects. The categories of Personal Information collected, the purposes for which such information is used, and the categories of third parties with whom such information may be disclosed are described in the “Collection of Personal Information,” “Use of Personal Information,” and “Disclosure of Personal Information” sections of this Privacy Policy, and the process for submitting requests is described in the “Choices and Access” section.

ADDITIONAL INFORMATION REGARDING QUEBEC, CANADA

The Quebec Bill 64 went into effect on September 1, 2023.

We reserve the right to update and amend this privacy policy in view of new laws and regulations and will take reasonable steps to ensure compliance with all applicable laws and regulations.

This Privacy Policy supplements, but does not replace, our Regulation S-P Privacy Notice, which governs client financial information.

The categories of Personal Information collected, the purposes for which such information is used, and the categories of third parties with whom information may be disclosed are described above in the “Collection of Personal Information,” “Use of Personal Information,” and “Disclosure of Personal Information” sections of this Privacy Policy.

Requests to exercise applicable rights may be submitted using the contact information provided in this Privacy Policy, and we will respond consistent with applicable law.