Privacy Policy

How we collect, use, and protect your personal and financial information.

Effective Date: January 1, 2026
Last Updated: January 1, 2026

ADP Workforce Management ("the Firm," "we," "us," or "our") is committed to protecting the privacy and confidentiality of your personal and financial information. As a registered investment advisor regulated by the Securities and Exchange Commission (SEC), we are required to comply with Regulation S-P (Privacy of Consumer Financial Information) and other applicable federal and state privacy laws. This Privacy Policy describes the types of information we collect, how we use and protect that information, and your rights regarding your personal data.

1. Information We Collect

In the course of providing financial advisory services, we collect personal information from various sources, including:

Information You Provide Directly

  • Full legal name, date of birth, Social Security number, and government-issued identification
  • Residential and mailing addresses, telephone numbers, and email addresses
  • Employment information, income, and compensation details
  • Financial account information, including bank accounts, brokerage accounts, retirement accounts, and insurance policies
  • Tax returns and related documentation
  • Net worth, assets, liabilities, and financial goals
  • Beneficiary and estate planning information
  • Risk tolerance assessments and investment preferences

Information from Third Parties

  • Account information from custodians and brokerage firms
  • Credit reports and financial background information (with your authorization)
  • Information from your other professional advisors (CPAs, attorneys) shared with your consent

Information Collected Automatically

  • Website usage data, including IP address, browser type, pages visited, and time spent on our site
  • Cookies and similar tracking technologies used to improve website functionality

2. How We Use Your Information

We use the personal and financial information we collect for the following purposes:

  • To provide investment advisory and financial planning services
  • To open and manage your investment accounts with our custodian partners
  • To develop and monitor your financial plan and investment portfolio
  • To communicate with you regarding your accounts, market updates, and our services
  • To comply with regulatory requirements, including SEC and FINRA reporting obligations
  • To detect and prevent fraud, money laundering, and other financial crimes
  • To respond to legal and regulatory inquiries
  • To improve our website and client experience

3. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties for marketing purposes. We may share your information in the following limited circumstances:

  • Service Providers: We share information with custodians (e.g., Charles Schwab, Fidelity), technology vendors, and other service providers who assist us in delivering our services. These providers are contractually obligated to protect your information and use it only for the purposes we specify.
  • Your Other Advisors: With your authorization, we may share information with your CPA, estate attorney, insurance agent, or other professional advisors to facilitate coordinated planning.
  • Regulatory and Legal Requirements: We may disclose information when required by law, regulation, subpoena, court order, or regulatory examination by the SEC, state securities regulators, or other governmental authorities.
  • Business Transfers: In the event of a merger, acquisition, or sale of our business, client information may be transferred as part of the transaction, subject to continued privacy protections.

4. Regulation S-P Compliance

In accordance with SEC Regulation S-P, we provide an annual privacy notice to all clients describing our information-sharing practices. You have the right to opt out of certain information-sharing arrangements with non-affiliated third parties. However, we do not share your nonpublic personal information with non-affiliated third parties except as described above or as otherwise permitted by law.

5. Data Security

We maintain comprehensive administrative, technical, and physical safeguards designed to protect your personal and financial information from unauthorized access, use, or disclosure. These safeguards include:

  • Encryption of sensitive data in transit and at rest
  • Multi-factor authentication for access to client accounts and internal systems
  • Regular security assessments and penetration testing
  • Employee training on data protection and cybersecurity best practices
  • Written information security policies and incident response procedures
  • Physical security measures at our office locations

While we take every reasonable precaution to safeguard your information, no method of electronic storage or transmission is completely secure. We regularly review and update our security measures to address evolving threats.

6. Data Retention

We retain your personal and financial information for as long as necessary to provide our services and comply with our legal and regulatory obligations. SEC regulations require us to maintain certain records for a minimum of five years after the termination of a client relationship, and some records must be retained for longer periods. When information is no longer required, we dispose of it securely using appropriate methods.

7. Your Rights

You have the following rights regarding your personal information:

  • Access: You may request a copy of the personal information we hold about you.
  • Correction: You may request that we correct inaccurate or incomplete information.
  • Opt-Out: You may opt out of receiving marketing communications at any time.
  • Account Closure: You may terminate your advisory relationship, subject to applicable account closure procedures.

To exercise any of these rights, please contact us using the information provided below. We will respond to your request within 30 days.

8. Cookies and Website Analytics

Our website uses cookies and similar technologies to enhance your browsing experience, analyze site traffic, and understand visitor behavior. You may configure your browser to refuse cookies, though this may limit certain features of our website. We do not use cookies to collect personally identifiable financial information.

9. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from a minor, we will take steps to delete it promptly.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, regulatory requirements, or applicable law. Material changes will be communicated to clients through our normal communication channels. The "Last Updated" date at the top of this policy indicates when it was most recently revised.

11. Contact Information

If you have questions about this Privacy Policy or our data protection practices, please contact us:

ADP Workforce Management
Attn: Chief Compliance Officer
200 Financial Center Blvd, Suite 1500
Your City, ST 60601
Phone: (555) 555-0100
Email: advisors@adpworkforces.com

This Privacy Policy is provided in addition to and supplements our Form ADV Part 2A (Firm Brochure), which contains additional information about our advisory practices and is available upon request or through the SEC's Investment Adviser Public Disclosure (IAPD) website at adviserinfo.sec.gov.