Privacy Policy

Our relationship with you is our most important asset. We understand that you have entrusted us with your private financial information, and we’ll do everything we can to maintain that trust.

This notice is being provided to you in accordance with the Securities and Exchange Commission’s rule regarding the privacy of consumer financial information (“Regulation S-P”). Please take the time to read and understand the privacy policies and procedures that we have implemented to safeguard your nonpublic personal information. *

We collect personal information to do financial planning and to perform our investment management responsibilities.

1 We do not sell your personal information to anyone. We may collect it for a specific purpose.

When you visit our website as an unregistered user, no personal data about you is collected by us. Only the current IP address of your computer, date and time, your browser type and computer operating system, along with a record of the pages on our site which you access and the searches you perform, is logged. It is not possible to identify you as a person from this information. The data about your visit is used purely for statistical and security purposes or to improve our website.

When you contact us directly or when you request additional informational content, we will collect personally-identifying information from you that may specifically include your name, email address, and telephone number.

2 We do not disclose any nonpublic information about our customers or former customers to anyone, except as permitted by law.

In accordance with Section 248.13 of Regulation S-P, in limited circumstances where we believe in good faith that disclosure is required or permitted by law, we may disclose all of the information we collect, as described above, to certain non affiliated third parties such as attorneys, accountants, auditors and persons or entities that are assessing our compliance with industry standards. We enter into contractual agreements with all non affiliated third parties that prohibit such third parties from disclosing or using the information other than to carry out the purposes for which we disclose the information.

Outside of this exception, we will not share your personal information with third parties unless you have specifically asked or granted us permission to do so. This Policy does not create rights enforceable by third parties.  We do not disclose personal information of our “customers”, as defined under the California “Shine the Light” Act, to third parties for direct marketing purposes.

We collect personal information in the normal course of business in order to provide planning and investment management services. We may however provide aggregate level information, to said contractual partners in which circumstances all reference to your personal information will be removed.

New client information. We collect information that you provide to us when you become a client. The information we collect includes name(s), address, phone number, email address, Social Security number(s), and other information about your investing and financial planning needs.

3 We protect the confidentiality and security of your personal information.

We restrict access to personal information to our staff and for business purposes only.

We maintain physical, electronic, and procedural safeguards to guard your personal information. We have implemented appropriate technical and organizational measures, such as limiting access to the data to authorized personnel only and storing data on a secure server or cloud-based service, to protect your personally-identifiable information against accidental or intentional manipulation, loss, destruction and access by unauthorized persons. Our security procedures are continually enhanced as new technology becomes available.

A cookie is a string of information that is sent by a website and stored temporarily in your computer’s memory. Cookies can recognize previous connections to our website by your computer; cookies can identify your computer. You can delete the cookies stored in your system file at any time. We employ cookies technology to facilitate quick login procedures and to personalize the website’s contents. If you delete the cookies from your computer, you will be asked to type in your username and password again.

4 We continue to evaluate our efforts to protect personal information and make every effort to keep your personal information accurate and up to date.

If you identify any inaccuracy in your personal information, or you need to make a change to that information, please contact us so that we may promptly update our records.

5 We will provide notice of changes in our information sharing practices.

If at any time in the future it is necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change so that you will have the opportunity to opt out of such disclosure. We may revise this Privacy Policy from time to time and post the new version on our website, which will be applicable upon posting. Please check our website from time to time and make sure that you are aware of the most recent version of this Privacy Policy. You will find the date that the policy was last revised at the top of this Privacy Policy.

How to Contact Us

Inquiries or requests for erasure of your information, where data is no longer necessary or not lawful to be possessed, should be made by contacting us.

Call: Jon Ulin, Managing Principal:  (561) 210-7887

* Nonpublic personal information means personally identifiable information and any list, description or other grouping of consumers that is derived using any personally identifiable financial information that is not publicly available.