SEC Regulation S-P, the “Privacy of Consumer Financial Information” rule, requires that we inform current and prospective clients about our policies concerning the collection and use of non-public client information.

Collection and Sharing of Clients’ Personal Information

Everspire collects certain non-public personal identifying information about clients (such as name, address, social security number, etc.) from the following sources:

• Information the client provides on applications or other forms;
• Account information including purchases and sales, balances, positions, and history;
• Information received about the client from consumer reporting agencies and account custodians.

Everspire may share a client’s personal information for the following reasons:

• For our everyday business purposes, such as processing client transactions, maintaining client accounts, or communicating with clients;
• For our affiliates’ everyday business purposes, such as sharing information about client transactions and experiences;
• In communication with outside entities when required, for example to respond to court orders and legal investigations, or report to credit bureaus
• For our own marketing to offer our products and services to clients;
• For joint marketing with other financial companies to offer our products and services to clients; or
• For non-affiliates to market to our clients.

If a client has opted out of certain sharing, Everspire will not share the specified information for that client.

If a client decides to close his or her account(s) or becomes an inactive customer, Everspire will continue to adhere to the privacy policies described here, as updated.

Safeguarding of Client’s Personal Information

Everspire restricts access to clients’ non-public personal information to those employees who need the information in order to service client accounts and trains those employees on Everspire’s privacy policies and procedures.

Everspire maintains physical, electronic, and procedural safeguards that comply with applicable federal or state standards to protect the client information that we gather, store, and archive. For example, the firm’s digital systems are protected through a combination of password use, encryption, two-factor authentication, and other measures. Third parties involved in the storage of Everspire client information are vetted and made aware of the importance Everspire places on both firm and client information security.

In addition to electronic protection, Everspire implements physical protocols such as the proper storage of physical client paperwork in secured locations and reasonable physical security measures at its home office location to prevent unauthorized access. Employees working from home must follow the same policies.

Everspire will retain records for at least 5 years, or as otherwise required by applicable state or federal law. If client non-public personal information is disposed of, Everspire will take reasonable measures to protect against its unauthorized access or use during the process.