Privacy Policy

1. Information We Collect

We collect information that allows us to provide thoughtful, personalized wealth management and to meet our regulatory obligations as a financial services firm. The categories of information we collect include:

Information You Provide Directly

• Contact details such as name, email address, phone number, and mailing address when you schedule a consultation, subscribe to communications, or become a client.
• Financial information including income, assets, liabilities, investment objectives, risk tolerance, and account information, when you engage us as your financial advisor.
• Identifying information such as date of birth, Social Security number, and government-issued identification, which we collect to comply with federal "Know Your Customer" and anti-money-laundering regulations.
• Family and beneficiary information shared as part of estate planning, generational wealth transfer, and family governance discussions.
• Communications you send to us, including emails, voicemails, and form submissions.

Information Collected Automatically

• IP address, browser type, device identifiers, and operating system.
• Pages viewed, time spent on the site, referring URLs, and other usage data collected via cookies and similar technologies.
• General location data inferred from your IP address.

Information from Third Parties

• Custodians, broker-dealers, and clearing firms (including Commonwealth Financial Network^®) that hold or service your accounts.
• Identity-verification services, credit reporting agencies, and other providers that help us confirm identity and meet legal obligations.
• Public databases and referral sources, when relevant to our engagement with you.

2. How We Use Your Information

We use the information we collect to deliver our services with care and to operate our business responsibly. Specifically, we use information to:

• Provide wealth management, financial planning, retirement, estate, tax, and insurance guidance.
• Open, administer, and service investment and advisory accounts on your behalf.
• Communicate with you about market conditions, planning opportunities, account activity, and firm updates.
• Respond to inquiries, schedule meetings, and follow up on consultations.
• Comply with applicable laws, regulations, and industry rules (including those of FINRA, the SEC, and the IRS).
• Detect and prevent fraud, unauthorized access, and other harmful activity.
• Improve our website, content, and the relevance of any marketing or educational materials.
• Fulfill any other purpose for which you provide the information, with appropriate notice.

3. How We Share Information

We do not sell your personal information. We share information only as necessary to provide our services and meet legal requirements. We may disclose information to:

• Affiliated firms and service providers, including Commonwealth Financial Network^® (our broker-dealer and Registered Investment Adviser), custodians, clearing firms, and insurance carriers.
• Professional partners such as attorneys, accountants, and tax preparers when you direct us to coordinate with them on your behalf.
• Technology and operations vendors who help us run our website, process communications, store data securely, and analyze website usage. These vendors are contractually bound to safeguard your information.
• Regulators and government authorities when required by law, subpoena, court order, or to protect the safety, rights, or property of Bay Harbor, our clients, or others.
• Successors in interest in connection with a merger, acquisition, or sale of all or a portion of our business, in which case appropriate confidentiality obligations will apply.

4. Cookies & Tracking Technologies

Our website uses cookies and similar technologies to improve your experience, remember your preferences, and understand how visitors use the site. Cookies are small data files stored on your device.

Types of Cookies We Use

• Essential cookies required for the website to function properly.
• Analytics cookies (including Google Analytics) that help us understand site usage so we can improve content and navigation.
• Functional cookies that remember your preferences and personalize your experience.

You can control cookies through your browser settings or opt out of Google Analytics at tools.google.com/dlpage/gaoptout. Disabling certain cookies may limit website functionality.

5. Data Security

We employ administrative, technical, and physical safeguards designed to protect the personal information in our care, including encrypted communications, restricted access controls, secure document storage, and regular review of our security practices. Our affiliated custodians and broker-dealer maintain industry-standard security measures consistent with FINRA and SEC expectations.

While we take reasonable steps to protect your information, no method of transmission over the internet or method of electronic storage is fully secure. We cannot guarantee absolute security, but we work continuously to protect what you entrust to us.

6. Your Rights & Choices

You have meaningful choices about your personal information. You may:

• Access and update the information we hold about you by contacting our office.
• Opt out of marketing communications by following the unsubscribe link in any email we send or by emailing us directly.
• Request restrictions on how we use your information, subject to applicable legal and regulatory requirements.
• Request deletion of personal information that is not required to be retained under financial industry recordkeeping rules.

We may need to verify your identity before responding to a request and may be unable to fulfill requests that conflict with our legal obligations as a financial services firm.

7. California Residents (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA) gives you additional rights with respect to the personal information we collect:

• The right to know what categories of personal information we collect, use, disclose, and (where applicable) sell.
• The right to request deletion of your personal information, subject to certain exceptions.
• The right to opt out of the sale of personal information. We do not sell personal information.
• The right not to be discriminated against for exercising any of these rights.

To exercise these rights, please visit Do Not Sell My Personal Information or contact us using the details below.

8. Third-Party Websites

Our website may contain links to third-party websites, including those of Commonwealth Financial Network^®, FINRA, SIPC, and educational resources. We are not responsible for the privacy practices or content of websites we do not operate. We encourage you to review the privacy policies of any third-party site you visit.

9. Children's Privacy

Our website and services are intended for adults. We do not knowingly collect personal information from children under the age of 13. If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to remove it.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we do, we will revise the "Last Updated" date at the top of this page and, where appropriate, provide additional notice. We encourage you to review this policy periodically.

11. Contact Us

If you have questions about this Privacy Policy or how your information is handled, we welcome the conversation.