Privacy Policy

SR99 Advisors – Privacy Policy

Last Updated: November 16, 2025

SR99 Advisors (“SR99 Advisors,” “Company,” “we,” “us,” or “our”) is committed to maintaining the confidentiality, integrity, and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you visit our website hosted on Wix.com (the “Site”) or engage our investment advisory services.

We comply with all applicable federal and state privacy laws, including but not limited to:
• California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)
• Gramm-Leach-Bliley Act (GLBA)
• SEC Regulation S-P (including 2024 amendments)
• SEC Rule 204-3 (Form ADV delivery)
• Applicable state regulations governing registered investment advisers

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By accessing the Site or using our services, you acknowledge and agree to the terms of this Privacy Policy.

1. Information We Collect

2. Information You Provide to Us

We may collect information you voluntarily submit through the Site, including:
• Full name
• Email address
• Phone number
• Mailing address
• General financial goals or planning needs
• Messages submitted through contact or scheduling forms

Important Notice:
We do not collect banking information, account numbers, Social Security numbers (SSNs), brokerage logins, or other sensitive financial information through the public Site.

Sensitive information is collected only after you engage SR99 Advisors as a client and only through:

1. Our encrypted client portal (“Vault”)

2. Encrypted email (PGP or S/MIME)

3. Direct secure transmission with your custodian (e.g., Schwab)

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If sensitive information is inadvertently submitted through the Site, it will be permanently deleted upon discovery.

B. Information Automatically Collected (Wix Platform)

Our hosting provider (Wix) automatically collects certain technical data, including:
• IP address
• Browser type and version
• Device and operating system information
• Pages viewed and time spent on the Site
• Cookies, pixels, tags, and similar technologies
• Security, diagnostic, and performance logs

This data is used solely for site functionality, analytics, and security monitoring.

C. Nonpublic Personal Information (NPI) – Clients Only

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Once you become a client, we may collect regulated Nonpublic Personal Information, such as:
• Account balances and holdings
• Financial statements and documents
• Investment objectives, suitability information, and risk tolerance
• Social Security number (only when required by law)
• Know Your Client (KYC) and Anti-Money Laundering (AML) information

NPI is never collected through the public website.

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D. Required Regulatory Disclosure – Form ADV Part 2A

Before entering an advisory agreement, all prospective clients must receive SR99 Advisors’ Form ADV Part 2A (“Firm Brochure”), which includes:
• Description of services
• Fee schedule and compensation
• Conflicts of interest
• Disciplinary disclosures (if any)
• Investment strategies and risks
• Custody and brokerage practices

A copy is available at any time upon request (see Section 14).

2. How We Use Your Information

We use your information solely for legitimate business, operational, and regulatory purposes, including:

Purpose

Examples

Provide Services

Respond to inquiries, assess suitability, deliver advisory services, provide Form ADV

Client Onboarding

Establish client portal access, verify identity, comply with KYC/AML requirements

Website Operations

Improve performance, protect security, analyze usage trends

Legal & Compliance

SEC/state filings, audits, regulatory examinations, subpoenas, recordkeeping obligations

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We do not use personal information for advertising or marketing unrelated to SR99 Advisors.

3. Legal Basis for Processing

We process data under one or more of the following legal bases:
• Consent (e.g., information submitted through a contact form)
• Contractual necessity (e.g., advisory services agreement)
• Legal and regulatory obligations (e.g., SEC, IRS, AML requirements)
• Legitimate interests (e.g., preventing fraud, enhancing security)

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4. How We Share Information

SR99 Advisors does not sell or share personal information for marketing or advertising purposes.

We may disclose personal information only as permitted by law:

Regulatory compliance, audits, examinations, or legal defense

All third parties are contractually obligated to maintain confidentiality and protect client information.

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5. California Residents – CCPA/CPRA Rights

If you are a California resident, you have the following rights:

*Right to Know what personal information we collect, use, disclose, or retain

*Right to Access a copy of your personal information (twice per 12 months)

*Right to Correction of inaccurate information

*Right to Deletion (subject to legal/regulatory retention requirements)

*Right to Opt-Out of Sale/Sharing (not applicable—we do not sell/share data)

*Right to Limit Use of Sensitive Information (we limit by default)

*Right to Non-Discrimination for exercising your rights

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6. GLBA & SEC Regulation S-P (Privacy Notice)

Privacy Protections

We maintain strict physical, technical, and administrative safeguards, including:
• Encryption of sensitive information (TLS 1.3, AES-256)
• Multi-factor authentication for client systems
• Role-based access controls (need-to-know basis)
• Vendor due-diligence and ongoing monitoring
• Secure disposal of physical and electronic records

We do not disclose NPI except as permitted or required by law.

Opt-Out Rights (GLBA)

You may opt out of non-required sharing with non-affiliated third parties by emailing:
“OPT OUT” to SR99advisors@gmail.com (include your name and contact information).
We will confirm your request within 30 business days.

Note: This right rarely applies because we share information only with service providers under contractual confidentiality.

Incident Response Program (Regulation S-P 2024 Amendments)

SR99 Advisors maintains a written Incident Response Program designed to:
• Detect and contain data breaches
• Assess whether compromise of customer information has occurred
• Notify affected individuals within 30 days if sensitive data is accessed or acquired
• Document and report incidents to regulators when required

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7. Data Security

We use industry-standard safeguards to protect information, including:
• Encryption in transit and at rest
• Firewalls and intrusion-detection systems
• MFA-protected portals
• Regular cybersecurity reviews and risk assessments
• Employee training on data protection and phishing prevention

No system is entirely secure, but we follow best practices applicable to financial and regulated firms.

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8. Data Retention

We retain personal information only as long as necessary for business, legal, or regulatory purposes:

• Website inquiries: retained up to 1 year
• Client records: retained 5–7 years under SEC/state rules (or longer if required)
• Requests for deletion are honored unless retention is required by law

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9. Cookies and Tracking Technologies

We use cookies for:
• Essential site functionality
• Security and fraud prevention
• Analytics (through Wix)

You may adjust browser settings to restrict cookies or use the cookie banner presented on your first visit.

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10. External Links

The Site may contain links to third-party websites.
SR99 Advisors is not responsible for the content or privacy practices of those external sites.

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11. Children’s Privacy

The Site and our services are not intended for individuals under 18.
We do not knowingly collect information from minors.

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12. Your Choices

You may request at any time:
• Access to your personal information
• Correction or deletion of your data
• A copy of Form ADV Part 2A
• Opt-out of GLBA-permitted sharing
• Unsubscribe from communications

Requests should be submitted using the contact information in Section 14.

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13. Changes to This Privacy Policy

We may update this Privacy Policy periodically.
Revisions will be posted on this page with an updated “Last Updated” date.
Material changes will be communicated to clients via email.

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14. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or would like a copy of Form ADV Part 2A, please contact us:

SR99 Advisors
Simi Valley, California, USA
Email: SR99advisors@gmail.com
Phone: (818) 470-6870