Privacy and Confidentiality Policy

Our Commitment to Privacy

Otley Wealth Management LLC is committed to protecting the privacy and confidentiality of our clients' personal and financial information. This Privacy and Confidentiality Policy outlines how we collect, use, protect, and share information in accordance with applicable federal and state privacy laws and regulations.

Information We Collect

To provide you with comprehensive wealth management services, we collect various types of information, including:

• Personal Information: Name, address, date of birth, Social Security number, and contact information
• Financial Information: Income, assets, liabilities, investment objectives, and risk tolerance
• Account Information: Account balances, transaction history, and holdings
• Employment Information: Occupation, employer, and employment history
• Other Information: Information from consumer reporting agencies, public records, and other sources as permitted by law

How We Use Your Information

We use the information we collect to:

• Provide wealth management and investment advisory services
• Process transactions and maintain your accounts
• Develop and recommend appropriate investment strategies
• Comply with legal and regulatory requirements
• Communicate with you about your accounts and our services
• Improve our services and client experience

Information Sharing and Disclosure

We do not sell your personal information to third parties. We may share your information only in the following circumstances:

• Service Providers: With companies that perform services on our behalf, such as custodians, broker-dealers, and technology providers
• Legal Requirements: When required by law, regulation, or legal process
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• With Your Consent: When you authorize us to share information with third parties
• Professional Advisors: With your attorneys, accountants, or other professional advisors as necessary to serve you

Security Measures

We maintain physical, electronic, and procedural safeguards to protect your personal information:

• Secure data encryption for electronic communications and storage
• Restricted access to personal information on a need-to-know basis
• Regular security assessments and updates to our systems
• Employee training on privacy and security protocols
• Secure disposal of information when no longer needed

Confidentiality

As a fiduciary, we maintain strict confidentiality regarding all client information. Our employees and associated persons are bound by confidentiality agreements and professional standards that prohibit the unauthorized disclosure of client information. We will not discuss your financial affairs with anyone without your explicit permission, except as required by law or necessary to provide our services.

Your Privacy Rights

You have the right to:

• Access and review the personal information we maintain about you
• Request corrections to inaccurate information
• Opt out of certain information sharing (where applicable)
• Receive our privacy notice annually
• File a complaint with us or regulatory authorities if you believe your privacy rights have been violated

Cookies and Online Tracking

Our website may use cookies and similar technologies to enhance your browsing experience and analyze site usage. You can control cookie settings through your browser preferences. We do not track your online activities across third-party websites.

Former Clients

We maintain the same privacy protections for former clients as we do for current clients. Your information remains confidential even after our advisory relationship ends.

Changes to This Policy

We reserve the right to modify this Privacy and Confidentiality Policy at any time. We will notify you of material changes as required by law. The most current version will always be available on our website or upon request.