Privacy Policy
Last updated: [DATE]
1. Scope
This Privacy Policy describes how [COMPANY LEGAL NAME] (“we”) collects, uses, and protects data through the Advisor Platform application (the “Service”). It covers two categories of people: (a) the RIA firm’s own staff who have accounts (“Users”), and (b) the firm’s advisory clients whose information Users enter into the Service (“Advisory Clients”). We are a data processor for Advisory Client data — the RIA firm is the data controller and is responsible for its own disclosures to its clients (e.g., its Form CRS / Regulation S-P privacy notice).
2. What We Collect
For Users (firm staff): name, work email, password (stored as a salted bcrypt hash, never in plaintext), role, and login activity.
For Advisory Clients (entered by Users): identity and contact information, date of birth, Social Security number, address, employment and financial profile, investment objectives and risk-tolerance answers, and AML/CIP-related fields (e.g., ID type, PEP status, source-of-funds). Sensitive fields (SSN, income, and net worth figures) are encrypted at rest with AES-256-GCM before being stored; see the README’s architecture notes.
We also store financial/accounting records the firm creates in the Service (invoices, journal entries, bank transactions the firm imports or enters), and an audit log of security-relevant actions (logins, role changes, record edits) for the firm’s own compliance recordkeeping.
3. How We Use It
Solely to provide the Service to the firm that entered it: authenticating Users, rendering client records back to that firm’s own Users, computing billing and analytics the firm requested, and maintaining the audit trail described above. We do not sell personal data, and we do not use Advisory Client data for advertising.
4. Third-Party Processors
We use Stripe to process the firm’s subscription payment for the Service itself — Stripe receives billing contact and payment details, not Advisory Client data. We use [DATABASE HOSTING PROVIDER] to host the application database, and [EMAIL PROVIDER, IF ANY] to send transactional email. If the firm enables an optional identity-verification, sanctions-screening, e-signature, or custodian-data integration in the future, that provider will process the specific data needed for that feature — see the in-app disclosures for each integration.
5. Data Retention
We retain data for as long as the firm’s subscription is active, plus a reasonable period after cancellation to allow export, unless the firm requests earlier deletion and we have no independent legal obligation (e.g., recordkeeping rules) to retain it longer.
6. Security
Passwords are hashed with bcrypt; sensitive Advisory Client fields are encrypted at rest; sessions are signed and can be revoked immediately firm-wide (e.g., on suspension) or per-user (e.g., on a password change) rather than only at next login. No method of storage or transmission is 100% secure, and we cannot guarantee absolute security.
7. Your Rights
A firm’s Users can access, correct, or export their firm’s data through the Service directly. An Advisory Client seeking to exercise a data-privacy right should contact their advisory firm directly, as the firm is the data controller for that information.
8. Contact
Questions about this Privacy Policy can be sent to [SUPPORT EMAIL].