Scope and Applicability
This Privacy Policy governs the collection, processing, storage, transfer, and use of personally identifiable information and technical metadata obtained through User access to and interaction with the AdvisorForInvestors digital platform located at advisorforinvestors.com and all associated subdomains, microsites, application programming interfaces, and ancillary digital services operated by AdvisorForInvestors LLC (hereinafter "the Company," "we," "us," or "our"). This Policy constitutes a binding legal agreement between the Company and any natural or legal person who accesses or uses the Platform in any capacity (hereinafter "User," "Data Subject," or "you"). Continued access to or use of the Platform following publication of this Policy constitutes unambiguous and affirmative consent to all data processing activities described herein. Users who do not consent to the terms of this Policy are prohibited from accessing or using the Platform and must immediately discontinue all use thereof and submit a data deletion request to the address provided in the contact section below.
Categories of Personal Data Collected and Legal Bases for Processing
The Company, acting in its capacity as Data Controller, collects personally identifiable information through multiple modalities. Information is voluntarily submitted by Users through web-based intake forms, lead generation mechanisms, newsletter subscription interfaces, and direct electronic communications, including but not limited to full legal name, primary and secondary electronic mail addresses, telephone numbers, residential zip codes, metropolitan statistical area designations, self-reported investable asset ranges, stated investment objectives, and risk tolerance disclosures. The Company also passively collects technical metadata including IPv4 and IPv6 addresses, browser fingerprinting data, session identifiers, device characteristics, operating system specifications, referral uniform resource locators, clickstream data, time-on-page metrics, and behavioral interaction logs. Additionally, the Company may receive User data from third-party advertising networks, social media platforms, data aggregators, or analytics providers to the extent permissible under applicable law. Processing of personal data is conducted on the following legal bases: contractual necessity for the provision of requested services; legitimate business interests of the Company in operating, improving, and securing the Platform; compliance with applicable legal and regulatory obligations; and express User consent where separately obtained and documented.
Purposes of Data Processing
The Company processes collected personal data for the following distinct and independent purposes: facilitation and fulfillment of investor-to-registered investment adviser matching and lead transmission services as explicitly requested by the User; transmission of electronic commercial communications, editorial newsletters, regulatory update notifications, and platform-related correspondence to Users who have affirmatively opted in to such correspondence; performance analytics, conversion rate optimization, and User experience research conducted to improve Platform functionality and service quality; fraud prevention, identity verification, security monitoring, automated bot detection, and compliance with applicable financial services regulatory requirements and recordkeeping obligations; enforcement of the Company's Terms and Conditions, Disclosure Policy, and all other governing legal agreements; data aggregation, de-identification, and statistical analysis for the purpose of generating industry benchmarking reports and market research publications; and compliance with valid legal process including subpoenas, court orders, regulatory investigations, and other compulsory disclosure demands issued by governmental or quasi-governmental authorities of competent jurisdiction.
Data Sharing and Third-Party Disclosure
The Company does not sell, rent, lease, barter, or otherwise transfer personally identifiable information to unaffiliated third parties for their independent commercial purposes. Notwithstanding the foregoing general prohibition, the Company may disclose User data in the following limited circumstances: to SEC-registered registered investment adviser firms specifically and exclusively selected by the User through the Platform's connection request functionality, limited to information necessary to fulfill the requested introduction and subject to the receiving firm's own privacy obligations; to authorized sub-processors, data processors, and service providers engaged by the Company under binding data processing agreements imposing confidentiality obligations and data security requirements no less protective than those described herein, including cloud infrastructure providers, electronic mail service providers, customer relationship management platforms, and web analytics vendors; to successors in interest in the event of a merger, acquisition, asset sale, corporate reorganization, or change of control, with advance notice provided to Users via conspicuous Platform announcement; and to law enforcement agencies, regulatory bodies, courts of competent jurisdiction, and other governmental authorities pursuant to valid legal process, or where disclosure is reasonably necessary to prevent imminent fraud, abuse, or harm to persons or property.
Cookies, Tracking Technologies, and Third-Party Analytics
The Platform employs first-party and third-party cookies, web beacons, pixel tags, local storage objects, session storage objects, and substantially similar client-side tracking technologies for the following purposes: maintenance of session continuity and authenticated user states; storage of User preferences, interface settings, and customization data; implementation of cross-session behavioral analytics and attribution modeling; facilitation of programmatic advertising services through third-party advertising networks where applicable; and enablement of third-party analytics platforms that collect and process Platform usage data under their own independent privacy policies. Users may manage cookie preferences through their browser's native privacy controls or through applicable opt-out mechanisms provided by third-party advertising networks, including the Digital Advertising Alliance's consumer opt-out portal and the Network Advertising Initiative's opt-out page. Certain categories of cookies are strictly necessary for Platform functionality and cannot be disabled without materially impairing the User experience.
Data Security, Retention, and Deletion
The Company maintains a comprehensive information security program comprising technical, administrative, and physical safeguards designed to protect personally identifiable information against unauthorized access, acquisition, disclosure, modification, destruction, or loss. Such safeguards include encryption of data in transit utilizing Transport Layer Security protocols, encryption of sensitive data at rest, role-based access controls implementing the principle of least privilege, multi-factor authentication for administrative system access, regular penetration testing and vulnerability assessments conducted by qualified third-party security professionals, and incident response procedures compliant with applicable state and federal breach notification statutes. The Company retains personally identifiable information for the minimum period necessary to fulfill stated processing purposes, subject to applicable statutory retention mandates and legitimate interests in the defense of legal claims. Transactional and lead data is retained for a period not exceeding thirty-six months from last User interaction; technical log data is retained for a period not exceeding twenty-four months; newsletter subscription data is retained for the subscription duration plus twelve months following confirmed unsubscription. Upon expiration of applicable retention periods, personal data is subjected to secure destruction using industry-standard sanitization protocols or irreversible anonymization.
Data Subject Rights and Access Requests
Subject to applicable jurisdiction and governing law, Users may possess certain rights with respect to their personal data, including the right of access to obtain confirmation of whether the Company processes personal data concerning the User and to receive a copy thereof in a commonly used format; the right to rectification of inaccurate or incomplete personal data maintained by the Company; the right to erasure of personal data subject to applicable legal retention obligations and legitimate business interests; the right to restriction of processing in circumstances defined by applicable law; the right to data portability in a machine-readable format where technically feasible; the right to object to processing activities based on the Company's legitimate interests; and, where processing is predicated on User consent, the right to withdraw such consent at any time without prejudicing the lawfulness of prior processing activities. Data Subject Access Requests must be submitted in writing to privacy@advisorforinvestors.com. The Company will acknowledge receipt and respond within the timeframe required by applicable law, which does not exceed thirty calendar days under most operative U.S. state privacy statutes.
Children's Privacy
The Platform is not directed to, and does not knowingly solicit or collect personally identifiable information from, individuals under the age of thirteen as defined under the Children's Online Privacy Protection Act, 15 U.S.C. Sections 6501 through 6506, or under the age of sixteen where required by applicable state law. In the event the Company determines that it has inadvertently collected personal information from a minor below the applicable age threshold without verifiable parental consent, such information will be promptly deleted from all Company systems and storage media. Individuals with knowledge that a minor has submitted personal information to the Platform without appropriate parental consent are requested to contact the Company immediately at privacy@advisorforinvestors.com.
Modifications and Governing Law
The Company reserves the right to amend, modify, update, or replace this Policy at any time in its sole and absolute discretion, subject to the requirement that material changes affecting User rights will be disclosed via conspicuous notice on the Platform homepage no fewer than fifteen calendar days prior to the effective date of such changes. Continued use of the Platform following the effective date of any modification constitutes affirmative acceptance of the amended Policy. This Policy is governed by and construed in accordance with the laws of the State of Arizona and applicable federal law, without regard to conflict of law principles. All privacy-related inquiries should be directed to privacy@advisorforinvestors.com.