Privacy Policy

Privacy Policy
CA Privacy Policy
GLB Privacy Notice

NFP Online Privacy Policy

Last Updated: May 23, 2023

This online Privacy Policy (“Privacy Policy“) applies to information about you obtained through www.fiducientadvisors.com (the “Site“) by Fiducient Advisors LLC (“we,” “us,” or “our“) and explains how we may collect, use, disclose, or otherwise process your personal information. It also sets forth the privacy options available to you regarding our use of your personal information and how to contact us about our privacy practices for the Site.

Please note that this Privacy Policy does not apply to any separate sites of our affiliated companies, subsites, or third-party sites that might be linked to, or accessible from, the Site. By visiting or using the Site, you agree with our collection, use and disclosure practices and other activities as described in this Privacy Policy.

Special Notice for International Users

If you are visiting this Site from outside of the United States, please be aware that the Site is operated from the United States. Accordingly, information we obtain through the Site will be transferred to, processed in, and stored in the United States. The data protection laws and regulations applicable to your personal information transferred to the United States may be different from the laws in your country of residence.

Information We Collect

Personal Information You Submit

In some circumstances, you may elect to provide us with certain personal information through the Site. For example, when you subscribe to a newsletter, register for an event, contact us through email, use our careers page or job postings, login to a portal, or request a proposal. Personal information you may submit through the Site includes your name, email address, phone number, company affiliation, education and employment background, or any other contact or personal information that you choose to disclose.

Information Collected Automatically

When you visit the Site, your internet browser may collect certain information through our use of first- and third-party cookies and tracking technologies without you taking specific actions to give us the personal information. Typically, this information will be related to your use of our Site, such as information about how you found our Site, what pages you visit, whether you had any technical issues, and the type of browser or device you use. Additional information about our use of cookies and other tracking technologies is provided in the “Use of Cookies and Tracking Technologies” section below.

Personal Information Collected from Other Sources

We may obtain some personal information about you from our vendors, affiliates, and business partners.

Use of Personal Information

We may use your personal information we obtain through the Site for various purposes, including to:

Provide services and products
Respond to your questions and other requests for information made through the Site
Send invitations to our conferences, webinars, and other events that we think may be of interest to you
Send our newsletter or other communications that you have requested or that may be of interest to you, in accordance with your preferences
Review and evaluate your candidacy when you submit information through our Careers page
Process your registration and manage your account through an online portal
Facilitate your use of the Site, including by tailoring Site features to you and improving your Site experience
Serve you advertisements or conduct other marketing activities
Enhance, improve or modify the Site, perform data analytics, identify usage trends, determine the effectiveness of our promotional campaigns, diagnose technical problems, and operate and expand our business activities
Prevent and address fraud, breaches of policies or terms, and other harm
Perform other functions as otherwise described at the time of personal information collection

Disclosure of Personal Information

We may disclose personal information obtained through the Site to affiliates that are under common ownership or control of our parent company, as well as to the following entities or in the following circumstances:

Service providers and business partners – We may disclose your personal information to our service providers, suppliers, subcontractors, and other parties who provide services to us or act on our behalf so that they can assist us with the provision, upkeep, and maintenance of the Site and other related activities, such as the organization of conferences and webinars, email delivery or auditing, or with the selection of applicants for job openings at NFP.
Sale, merger, and other corporate transactions – We may disclose your personal information in connection with a business transaction, including negotiations of such transactions. Such transactions may include a corporate reorganization, sale, merger, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business assets.
Legal compliance – When we believe it is necessary or appropriate under applicable laws, we may disclose your personal information to law enforcement, government authorities, regulatory bodies, or other parties in order to comply with laws, regulations, court orders, or other legal obligations, or to assist in investigations and help prevent other harms.
Fraud prevention and protection of legal rights – When we believe it is necessary to enforce our terms and conditions; to investigate, prevent, or respond to suspected illegal or fraudulent activity; to protect the safety, rights, or property of NFP or of our affiliates, users, or others; to exercise or protect legal rights or defend against legal claims; or to allow us to pursue available remedies or limit the damages that we may sustain.

Children‘s Privacy

The Site is not intended for, nor targeted to, children under 16, and we do not knowingly collect any personal information from children under 16. If we become aware that an individual submitting information is under 16, we will delete the information in accordance with applicable law.

Links to Other Websites

The Site may contain links to other websites or online services for your convenience and information. These may include social networking platforms such as Facebook, LinkedIn, Instagram, and Twitter, which may permit interactions that you initiate between the Site and the social networking platform. NFP is not responsible or liable for the content or privacy policies of websites or services that it does not control, and the inclusion of a link to another website or online service does not imply NFP’s endorsement.

We encourage you to review the terms, policies, privacy statements, and settings of these other platforms to learn more about their data practices.

Use of Cookies and Tracking Technologies

We use cookies and other types of tracking technologies (collectively, “Cookies”) on the Site to collect and analyze information about visitors’ interactions with the Site. The Cookies we use are placed by us or by our vendors. We and our vendors may link the information collected by Cookies to other information collected about you.

What are Cookies?

A cookie is a small text file saved by your internet browser when you visit a website. Cookies may carry out various functions; for example, they may (1) store information to help our Site function properly; (2) recognize your device when you visit our Site again; and/or (3) help us understand your use of our Site over time. We may use cookies to:

enhance your experience on our Site by improving navigation speed;
recognize your preferences, so that you do not need to enter the information each time you visit the Site;
customize your browsing experience on our Site by showing you information more likely to be relevant to you; or
learn about your visit to our Site, for example, by collecting information about which pages on our Site you viewed or links you clicked and how you interacted with our content during your visit or over multiple visits.

We may use a type of tracking technology called web beacons (or pixel tags or clear GIFs). Web beacons are an often invisible way to see if someone has used or accessed certain content. We primarily use web beacons to help us understand which areas of our Site are most popular with our visitors and to improve and update the content on our Site in response. Additionally, web beacons can help us measure the effectiveness of our advertising, for example, by counting the number of individuals who visit our Site or click a link within it.

We also may use tracking scripts. A tracking script is piece of programming code designed to collect information about your interactions with the Site. It is temporarily downloaded onto your device and is active while you are connected to the Site. The tracking script is typically deleted or deactivated thereafter.

What information do Cookies collect and store?

Cookies frequently store the name of the website and a unique ID associated with your browser or device. This information allows the relevant website to retrieve or provide the correct information. Each Cookie, for example, retrieves information it stores or provides information related to the Cookie.

Cookies are typically used to collect and store your personal preferences (such as your time zone or font size preferences), information needed to authenticate you as a valid website visitor, your IP address, your location during your site visit, the type of device you use and its operating system, and information about your use of a website, such as the links you click, how often you visit the website, and how you arrive at the website. For Google signed-in users, account information such as search history, YouTube history and data from sites that partner with Google may provide aggregated and anonymized insights into a user’s cross device behavior.

How do you opt out of Cookies?

Depending on your browser and geographical location, you may be able to block the use of Cookies when you visit our Site. Please note that blocking some types of Cookies may adversely affect your ability to use our Site, or hinder certain functionality on the Site.

Opting Out of Cookies Using Self-Regulatory Programs – Two self-regulatory programs are available to help consumers control the use of Cookies on their browsers—the Digital Advertising Alliance and the Network Advertising Initiative. Both programs help to regulate vendors in the digital advertising space. One function of their self-regulatory programs is to give you the ability to opt out of targeted (or interest-based) advertising, including Cookies, from their member companies. You can visit Ad Choices for the Digital Advertising Alliance’s WebChoices tool to review your opt outs. The Network Advertising Initiative assists with opt outs through their Opt Out of Interest-Based Advertising webpage.
Opting Out of Cookies Using a Browser – You may be able to disable Cookies using your browser settings. Please review your browser’s instructions, or visit All About Cookies (an unaffiliated website) for general information. Your browser settings may allow you to transmit a “Do Not Track” signal when you visit websites. Given the current lack of industry consensus regarding “Do Not Track” signals, our Site does not currently recognize them.
You may choose whether to permit Cookies from Google Analytics by using Google’s Opt-Out Browser Add-On.

Security

We take reasonable technical, organizational and administrative measures to protect personal information collected through this Site against unauthorized or unlawful processing and against accidental loss, destruction, or damage. However, because transmission via the Internet and online digital storage is not completely secure, we cannot guarantee the security of any information we may have collected from or about you through the Site.

Your Choices

If you no longer want to receive emails or marketing-related materials from us, you may opt out of receiving these materials by following the unsubscribe instructions in such messages or by contacting us as indicated in the “Contact Us” section below. Please note that even if you opt out of receiving promotional emails from us, we may continue to send you transactional or informational email communications.

Changes

We may modify or supplement this Privacy Policy from time to time, in which case we will post the updated Privacy Policy here and change the “last updated” date at the top of this page. You should check this page regularly to review changes to this Privacy Policy.

Your continued use of this Site after we have posted changes to this Privacy Policy will indicate that you agree with our changes. If any change to this Privacy Policy is unacceptable to you, please discontinue your use of the Site.

Contact Us

If you have questions regarding this Privacy Policy or our personal information handling practices, please contact the NFP Privacy Office as follows:

Email: privacyoffice@nfp.com

Postal Address:

NFP
c/o Privacy Office
1250 Capital of Texas Highway, Suite 600
Austin, TX 78746

Toll-Free Phone: (866) 824-3817

Notice To California Consumers

We provide the following Privacy Notice (“Notice”) in accordance with the California Consumer Privacy Act of 2018, as amended, (“CCPA”) to give California consumers information about how we collect, use and disclose their personal information, and about the rights and choices we offer California consumers regarding our processing of their personal information.

Bold terms throughout this Notice are used as defined in the CCPA.

WHO WE ARE

Fiducient Advisors LLC (“we”, “us” or “Fiducient”) provides investment advisory and consulting services to corporate and individual clients.

This Notice describes how Fiducient collects, handles and otherwise processes personal information in relation to your use of any of the services, websites and apps we offer (collectively, the “Services”). The Notice is a statement of our practices and of rights regarding your personal information and is not a contractual document, and does not create any rights or obligations on either party, beyond those which already exist under data protection laws. This Notice is intended to meet the requirements of the CCPA as amended. Bolded terms not otherwise defined in this Notice have the same meaning as set forth under the CCPA.

This Notice covers those applicable Services offered by Fiducient in California to consumers and their households, however this Notice does not apply, and excludes Services of our companies, as follows:

For our offices and operations conducted outside of California
For our offices and operations with separate privacy policies or that do not incorporate this Notice
When we act as a business associate to covered entities in connection with receiving Protected Health Information as defined under the Health Information Portability and Accountability Act (“HIPAA”)
When we collect personal information subject to the Gramm Leach Bliley Act (“GLBA”), such as when you apply for, or obtain, a financial product or service from us
When we act as service provider since we are processing personal information only on behalf of our clients, often pursuant to a written engagement or formal broker of record engagement, and then only to provide our service pursuant to such engagement
To personal information that was collected from a consumer in connection with being a job applicant, employee or independent contractor

PERSONAL INFORMATION WE COLLECT, USE AND DISCLOSE

We collect personal information about California consumers as summarized in the table below. Where we disclose personal information, such as to our service providers, we do so for the same business purposes described below and where appropriate, require that such parties maintain its confidentiality and maintain appropriate systems and processes to ensure its security and protection. These examples may vary depending on the nature of your interactions with us.

Category	Examples	Sources	Business Purposes	Recipients
Identifiers	Name, postal address, IP address, email address, account name, social security number, driver’s license number, passport number	Consumer Business partners Clients	Providing Services Security Compliance & operations Research & development Quality control & audit	Business partners Our companies* Government entities Service Providers Operating systems and platforms
Customer/ Individual Records	Name, address, telephone number, email address, signature, education, employment, employment history, bank account number, credit card number, debit card number,	Consumer Business partners Clients	Providing Services Security Compliance & operations Research & development Quality control & audit	Business partners Our companies* Government entities Service Providers Operating systems and platforms
Protected Characteristics	Marital/familial status, race, religion, disabilities	Consumer Business partners Clients	Providing Services Security Compliance & operations Quality control & audit	Business partners Our companies* Government entities Service Providers Operating systems and platforms Business/asset purchasers **
Commercial Information / Purchase Details	Purchase history or tendencies	Consumer Business partners	Providing Services Compliance & operations Research & development	Business partners Service Providers Our companies* Business/asset purchasers **
Internet Usage Information	Browsing history, search history, information regarding interactions with our website or advertisements	Consumer	Security Compliance & operations Research & development Quality control & audit	Business partners Service Providers Our companies* Operating systems and platforms
Geolocation Data	Approximate location inferred from your device IP Address	Consumer	Providing Services Compliance & operations Research & development	Business partners Service Providers Our companies* Operating systems and platforms
Sensory Data	Audio recordings of customer service calls, CCTV footage	Consumer	Providing Services Security Compliance & operations Quality control & audit	Business partners Service Providers Our companies* Operating systems and platforms
Professional or Employment Information	Professional, educational, or employment-related information	Consumer	Providing Services Security Compliance & operations Quality control & audit	Business partners Service Providers Our companies* Government entities
Inferences from PI Collected	Customer profiles reflecting preferences and predispositions	Consumer Business partners	Providing Services Research & development	Business partners Service Providers Our companies* Operating systems and platforms

* We work closely with other businesses and companies that fall under Fiducient and its affiliates and subsidiaries, which may or may not be Fiducient branded

** We will not disclose your personal information to others except to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our companies’ business, or a sale, liquidation, or transfer of some or all of our companies’ assets. In these situations, we will use reasonable efforts to ensure any such purchaser uses personal information transferred in accordance with this Notice.

Disclosure of Personal Information

We may disclose each of the categories of personal information identified above to the respectively identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the personal information was collected, including:

Auditing our ads;
Helping to ensure security and integrity of your personal information;
Debugging, repairing, and improving functionality;
Short-term, transient use;
Performing services on our behalf;
Internal research for technological development; and
Verifying the quality and/or safety of our Services and infrastructure.

In addition to the other purposes for collection, use, and disclosure of personal information described in this Notice, we may collect, use and disclose personal information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions or investigations. Likewise, we may use and disclose personal information to other parties in connection with the sale, assignment, merger, reorganization, or other transfer.

Children’s Information

We do not knowingly collect or sell personal information of children under the age of 16. Our Services are marketed towards corporate entities and adults. If we are notified that we have collected personal information of a child under the age of 16, we will delete the information as quickly as possible.

CALIFORNIA CONSUMER PRIVACY RIGHTS

California consumers have the following rights regarding their own personal information. Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive personal information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you. To exercise any of these rights, please submit a request to privacyoffice@nfp.com or call us at (866) 824-3817. Please note that, if you submit a request to know, request to delete, or request to correct, you will be asked to verify your identity in accordance with the law. You may designate an authorized agent to make a request on your behalf; however, you may need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above. We will never discriminate against you for choosing to exercise any of your privacy rights.

Right to Know. You have the right to know what personal information we have collected about you, which means you may ask for:
1. The categories of personal information we have collected about you, including
  - the categories of sources from which the personal information was collected;
  - our business or commercial purposes for collecting and disclosing personal information;
  - the categories of recipients to which we disclose personal information; and/or
  - the categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of personal information.
2. The specific pieces of personal information we have collected about you.
Right to Delete. You can request personal information be deleted.
Right to Correct. If you believe that personal information we have about you is inaccurate, you have the right to request that we correct that information.
Right to Opt Out of Sales and Sharing of Personal Information. We do not sell your personal information or share your personal information for cross-context behavioral advertising.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.

HOW WE STORE AND KEEP YOUR PERSONAL INFORMATION SECURE

We implement industry-standard technical, organizational, administrative and physical measures to help ensure a level of security appropriate to the risk to the personal information we collect, use, disclose and otherwise process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to help ensure the security of the processing. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable. We restrict access to your personal information to those who require access to such information for legitimate, relevant business purposes. We seek commitments of confidentiality, security and proper use from service providers we engage to process personal information.

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period that enables us to:

maintain business records for analysis and/or audit purposes;
comply with our record retention requirements under the law and our corporate policies;
defend against or bring any existing or potential legal claims; and/or
deal with any complaints regarding the Services.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the personal information.

CALIFORNIA’S SHINE THE LIGHT LAW

California law (referred to as the “Shine the Light” law) permits customers in California to request certain details about how their “personal information” (as defined by California Civil Code Section 1798.83/84) is disclosed to other parties for direct marketing purposes.

We do not disclose personal information to other parties for those parties’ own direct marketing purposes. Californians may request information about our compliance with this law and our personal information handling practices by contacting as set forth in the How to Contact Us section below.

Your inquiry must specify “California Privacy Rights Request – California Civil Code 1798.83/84 Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state and ZIP code.

HOW TO CONTACT US

The Fiducient subsidiary providing you Services is primarily responsible for the personal information collected in relation to that Service, and your relationship managers at such firms can serve as a contact for your questions or concerns.

You may also contact the Fiducient privacy office as follows:

Email: privacyoffice@nfp.com

Address:

NFP

c/o Privacy Office

1250 Capital of Texas Highway, Suite 600

Austin, TX 78746

Toll-Free Phone: (866) 824-3817

CHANGES TO THIS NOTICE

We reserve the right to make changes to this Notice at any time consistent with applicable local laws. Such changes will be posted on our website (www.fiducientadvisors.com). We encourage you to review this Notice periodically for any updates or changes.

This Notice is effective as of May 23, 2023.

Fiducient Advisors’ GLB Privacy Notice