Privacy Policy

Stephen Smith Financial Inc. ("SSF," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you visit our website at www.stephensmithfinancial.com, use our client portal, or interact with our Lenz AI assistant.

By using our website or services, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our website or services.

SSF is a registered investment adviser with the U.S. Securities and Exchange Commission ("SEC") and is subject to applicable federal and state privacy laws, including Regulation S-P (Privacy of Consumer Financial Information).

Information You Provide Directly. We collect information you voluntarily provide when you use our services, including: your name, email address, phone number, mailing address, financial information you share in connection with our advisory services, and any other information you submit through contact forms, the client portal, or communications with us.

Client Portal Information. When you register for or use our client portal, we collect your email address, password (stored in encrypted form), phone number, and any documents or information you upload to the portal, including tax returns and financial statements.

Lenz AI Assistant Interactions. When you use the Lenz AI chat feature, we collect the content of your questions and conversations. These interactions are processed by third-party AI services. Please do not share sensitive personal information such as Social Security numbers, account numbers, or passwords through the Lenz chat interface.

Automatically Collected Information. When you visit our website, we automatically collect certain technical information, including your IP address, browser type and version, operating system, referring URLs, pages visited, and the date and time of your visit. This information is collected through standard web server logs and analytics tools.

Cookies and Similar Technologies. We use cookies and similar tracking technologies to enhance your experience on our website, maintain session state in the client portal, and analyze website traffic. You may configure your browser to refuse cookies, though some features of our website may not function properly as a result.

We use the information we collect for the following purposes:

• To provide, operate, and improve our investment advisory services and website
• To communicate with you about your account, our services, and your inquiries
• To process and respond to your requests, questions, and feedback
• To authenticate your identity and maintain the security of the client portal
• To comply with applicable legal and regulatory requirements, including SEC and FINRA rules
• To detect and prevent fraud, unauthorized access, and other harmful activities
• To analyze usage patterns and improve the functionality of our website and services
• To send you information about our services, events, or educational content (with your consent where required)

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

Service Providers. We may share your information with trusted third-party service providers who assist us in operating our website, conducting our business, and providing services to you. These providers are contractually obligated to keep your information confidential and use it only for the purposes for which it was disclosed.

Affiliated Entities. We may share information with Stephen Smith Insurance Inc., our affiliated insurance entity, when you request information about or purchase insurance products. Any such sharing is conducted in accordance with applicable privacy laws.

Custodians and Financial Institutions. In connection with our investment advisory services, we may share your information with broker-dealers, custodians, and other financial institutions as necessary to execute transactions and maintain your accounts.

Legal Requirements. We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court order, subpoena, or regulatory inquiry), including to meet national security or law enforcement requirements.

Business Transfers. In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any such change in ownership.

We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include encrypted data transmission (SSL/TLS), password hashing, access controls, and secure cloud storage.

However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your portal login credentials.

In the event of a data breach that affects your rights and freedoms, we will notify you and applicable regulatory authorities as required by law.

As a registered investment adviser, SSF is subject to Regulation S-P, which governs the privacy of consumer financial information. Under Regulation S-P, we are required to provide you with a notice of our privacy practices at the time you become our client and annually thereafter.

We do not disclose nonpublic personal information about our clients or former clients to nonaffiliated third parties except as permitted by law — for example, to service providers who assist us in providing advisory services, or as required by legal process.

You have the right to opt out of certain disclosures of your nonpublic personal information to nonaffiliated third parties. To exercise this right or to request a copy of our full Regulation S-P privacy notice, please contact us at the information provided below.

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, to provide our services, and to comply with our legal and regulatory obligations. As a registered investment adviser, we are required by SEC rules to retain certain records for a minimum of five years.

When your information is no longer needed, we will securely delete or anonymize it in accordance with our data retention policies and applicable law.

Depending on your location and applicable law, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request that we correct inaccurate or incomplete information
• Deletion: Request deletion of your personal information, subject to our legal retention obligations
• Opt-Out: Opt out of marketing communications at any time by contacting us or using the unsubscribe link in our emails
• Portability: Request a copy of your data in a structured, machine-readable format where technically feasible

To exercise any of these rights, please contact us using the information below. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

Our website may contain links to third-party websites, including scheduling tools, YouTube, and regulatory resources. This Privacy Policy does not apply to those third-party sites, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

Our Lenz AI assistant is powered by third-party artificial intelligence services. Interactions with Lenz may be processed and stored by those services in accordance with their own privacy policies. Please do not share sensitive personal or financial information through the Lenz chat interface.

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you believe we have inadvertently collected information from a child under 18, please contact us immediately and we will take steps to delete that information.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify you by email or through a notice on our website.

Your continued use of our website or services after any changes to this Privacy Policy constitutes your acceptance of the updated policy. We encourage you to review this page periodically.