Investment advisors are required by law to inform consumers and customers of their policies regarding their handling of non-public personal information (“NPI”). At Evolve Wealth Advisors LP and its Affiliates (collectively, “Evolve Wealth Advisors,” “we,” our,” or “us”), due to the relationships that we have with our clients, we consider ourselves bound by professional standards of confidentiality that are even more stringent than those required by law, and it is an objective of the company to protect the privacy of all clients and customers. We understand that keeping your personal information private is an important concern, and we want you to understand how we gather and use NPI to provide services to you.
types of npi we collect
We collect NPI about you that is either provided to us by you or obtained by us with your authorization. This information can include, but is not limited to, your name, address, phone number, email address(es), social security number, date of birth, banking information, financial account numbers and/or balances, sources and amounts of income and expenses, assets and liabilities, and, in very limited cases, credit card numbers and/or information.
where we may obtain this information
We may collect information directly from you on applications, website input fields, and other forms that you complete. Additionally, we obtain information about your transactions with us and others such as custodians, broker/dealers, and other companies. With your consent, we may also obtain information from your other advisors and professionals.
For everyday business purposes – such as to process your transactions, maintain your account(s), provide investment management advice and services to you, or report to credit bureaus
For exceptional business purposes – if a merger, acquisition, debt financing transaction, sale of our assets, bankruptcy, insolvency, or receivership occurs, that requires us to disclose NPI that is necessary or incidental to those purposes and to the third party involved
To you and persons whom we believe to be your authorized agent(s) or representative(s)
For regulatory purposes – as when, from time to time, we may be required to give information about our business and customers to regulatory authorities or to respond to judicial process
For our marketing – to offer our products and services to you
For joint marketing with other financial companies; and
For our affiliates’ everyday business purposes – information about your transactions and experiences and information about your creditworthiness.
We do not sell your NPI.
If you are a new customer, we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information as described in this notice; however, you can contact us at any time to limit our sharing, as described below, and provided by law.
parties to whom we disclose
Like most modern businesses, we may need to share personal information to run our everyday operations. We do not disclose any NPI about our customers or former customers inconsistently with this policy without express authorization, except where we are compelled to do so by law. We restrict access to NPI internally to those employees and officers who require that information to provide our products and services to you. We want to assure all our clients, past, present, and future, that we safeguard the NPI provided to us and only use it for necessary business purposes and with the utmost of integrity, discretion, and professional judgment. In the section below, we list the reasons that we may share your NPI:
federal law gives you the right to limit sharing - opting out
Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for affiliates’ everyday business purposes, information about your creditworthiness; or sharing with affiliates or non-affiliates who use your information to market to you. State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately if you choose to opt out of these types of sharing.
other rights and remedies
To the extent permitted by the law of the state where you reside, you may request to have your NPI corrected if, for example, it is incomplete or incorrect. You may also opt out of receiving marketing material at any time, and you may, if you believe that your NPI has been used inappropriately, file a complaint with your local government privacy officer or ombudsperson, if such an office has been established. If you believe that your information has not been used properly, please contact us about the matter so we can speak with you and remedy the situation immediately and directly between us.
PROTECTING CONFIDENTIALITY OF CURRENT AND FORMER CLIENT’S INFORMATION
To protect your personal information from unauthorized access and use, we employ security measures that we believe are reasonably designed to protect the security and confidentiality of your information and that comply with federal law. These measures include confidentiality agreements with companies with whom we contract to provide services, password-protected user access to our computer files, training of employees, and strict policies for our employees regarding the use of confidential information.
We require third parties who assist us in providing our services to you to protect the personal information that they receive from us, including our customers’ and clients’ NPI.
changes to our policy
Regarding the use of certain types of personal information, Evolve Wealth Advisors is governed by the terms of the: California Consumer Privacy Act (“CCPA”).
Affiliates – companies related by common ownership or control including financial and non-financial companies
Non-affiliates – companies not related by common ownership or control including financial and non-financial companies
Joint marketing – a formal agreement between non-affiliated financial companies that together market financial products or services to you.
To the extent permitted by applicable law, we retain your NPI for the period necessary to serve the purposes for which it was provided or obtained. We may also retain the information beyond such a period to comply with applicable laws and regulations and to comply with our contractual obligations, legal and regulatory obligations, legal claims, or another legitimate interest.
Please call us if you have any questions. Your privacy, our professional ethics, and the ability to provide you with quality financial services are very important to us.