Privacy Policy — Farther

Notice of Privacy Practices

Last updated January 14, 2026

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1. INTRODUCTION

Farther Finance Advisors (“Advisors”) is a Delaware limited liability company and a registered investment adviser with the U.S. Securities and Exchange Commission (SEC). Advisors is affiliated with Farther Finance, Inc. (collectively, “Farther”, “we”, “our”, or “us”).

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Farther is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, share, and protect information about you in connection with our investment advisory services and through our website.

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Our Commitment to Your Privacy

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Your privacy is not for sale. We do not sell your personal information to anyone, for any reason, at any time. We maintain physical, electronic, and procedural safeguards designed to protect your information in compliance with federal securities laws and regulations, including the Gramm-Leach-Bliley Act and SEC Regulation S-P, as well as California state privacy laws.

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2. SCOPE AND APPLICABILITY

This Privacy Policy applies to:

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Current and prospective clients of Advisors’ investment advisory services
Website visitors who interact with our website
Other individual persons who provide us with personal information or with whom we communicate

Important Distinctions

The privacy protections and rights that apply to you depend on your relationship with us:

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Existing Clients (Customers): If you have established an ongoing advisory relationship with Advisors by entering into an investment advisory agreement, you are a "customer" under federal law. Your personal information is protected by the federal Gramm-Leach-Bliley Act (GLBA) and SEC Regulation S-P. For California residents who are existing clients, personal information we collect and use pursuant to GLBA for providing financial services is generally exempt from the California Consumer Privacy Act (CCPA) under the GLBA exemption. However, information collected or used for purposes outside the scope of GLBA (such as marketing or website analytics) remains subject to CCPA. See Section 8.1 for detailed information about the scope of the GLBA exemption.

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Prospective Clients: If you have inquired about our services, submitted information through our website, or are considering becoming a client but have not yet entered into an advisory agreement, you are a "prospective client." Information we collect about you before you become a customer is not covered by the GLBA exemption and is therefore subject to the California Consumer Privacy Act (CCPA) if you are a California resident, in addition to our comprehensive data security safeguards under federal law.

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Website Visitors: If you visit our website without providing personal information or establishing a business relationship, certain information may be collected automatically through cookies and similar technologies as described in Section 11 below.

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3. INFORMATION WE COLLECT

To provide investment advisory services and operate our business, we collect various categories of personal information. The specific information we collect depends on your relationship with us and the services you request.

3.1 Categories of Information Collected

Identifiers and Contact Information

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Full legal name, alias, or nickname
Postal address (residential and business)
Email address
Telephone numbers (mobile, home, work)
Social Security number or Tax Identification Number
Driver's license number or state identification card number
Passport number
Account numbers and online identifiers
Signature
Date of birth

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Financial Information

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Bank account numbers and routing information
Investment account numbers and credentials (with your authorization)
Credit card and debit card numbers
Financial account information, balances, and transaction history
Assets, liabilities, income, and expenses
Net worth and sources of wealth
Investment holdings and portfolio information
Credit reports and credit scores
Tax returns and tax identification information
Employment information and salary details
Retirement account information and beneficiary designations

Investment and Advisory Information

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Investment objectives and financial goals
Risk tolerance and investment experience
Investment time horizon and liquidity needs
Tax considerations and tax planning information
Estate planning information and documents
Financial planning needs and preferences

Professional and Demographic Information

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Employer name and address
Job title, position, and work history
Professional licenses and certifications
Business contact information
Age, date of birth, and marital status
Citizenship status
Education history and degrees obtained

Sensitive Personal Information

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Under federal and California law, certain categories of personal information are considered "sensitive" and receive enhanced protections:

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Social Security number, driver's license number, state identification card number, or passport number
Financial account numbers in combination with security codes, access codes, or passwords that permit access to an account
Precise geolocation (if you use our mobile applications with location services enabled)
Biometric information (such as fingerprints or voice recordings if used for authentication)
Health information (to the extent relevant for insurance planning)
Contents of mail, email, or text messages not directed to us
Genetic data

Internet and Electronic Activity Information

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When you visit our website or use our client portal:

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Device information (type, operating system, browser)
IP address and general location information
Browsing history and activity on our website
Search history on our website
Interaction with our emails and advertisements
Cookie and tracking technology data
Login credentials and authentication information

Audio and Visual Information

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Voice recordings of telephone calls with our customer service representatives for quality assurance, training, and security purposes
Video recordings from security cameras in our offices
Photographs if provided for identification verification
Electronic signatures

Professional Inferences

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We may develop inferences about you based on the information we collect to create a profile reflecting your investment preferences, financial characteristics, and advisory needs.

3.2 Sensitive Customer Information (Federal Definition)

Under SEC Regulation S-P, "sensitive customer information" means any component of customer information, alone or in combination with other information, the compromise of which could create a reasonably likely risk of substantial harm or inconvenience to an individual. This includes:

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Social Security number
Driver's license number or government-issued identification number
Account numbers in combination with security codes or passwords
Biometric records
Medical and health information
Credit or debit card numbers in combination with security codes

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We use and disclose sensitive customer information only for purposes permitted by law, such as providing the services you request, preventing fraud, maintaining security, and complying with legal obligations.

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4. HOW WE COLLECT INFORMATION

We collect personal information from various sources:

4.1 Directly From You

We collect most personal information directly from you when you:

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Complete account applications, forms, questionnaires, and agreements
Communicate with us by phone, email, mail, or in person
Use our website, client portal, or mobile applications
Provide us with documents, records, and supporting materials
Submit inquiries through our website contact forms
Participate in surveys or provide feedback
Attend our events or webinars

4.2 Automatically From Your Use of Our Services

We automatically collect certain information when you interact with our digital services:

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Website and Client Portal Usage: Through cookies, web beacons, and similar technologies, we collect information about your browsing activity, pages viewed, links clicked, and time spent on our website
Device Information: Information about the devices you use to access our services, including IP address, device type, operating system, and browser type
Electronic Communications: Information about whether you open our emails and which links you click

4.3 From Affiliates

We may receive information about you from our affiliated entities if you have relationships with multiple entities within our corporate family or if one affiliate refers you to us.

4.4 From Your Financial Institutions

With your authorization, we collect information about your accounts, holdings, balances, and transactions from:

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Banks and credit unions
Brokerage firms and custodians
Investment companies and mutual fund providers
401(k) and retirement plan administrators
Account aggregation services that facilitate access to your financial information

4.5 From Your Professional Advisors

With your consent or at your direction, we may receive information from your:

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Attorneys and estate planning counsel
Certified Public Accountants (CPAs) and tax preparers
Insurance agents and brokers
Other financial advisors

4.6 From Service Providers and Third Parties

We receive information from third-party service providers and vendors, including:

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Identity Verification Services: To verify your identity and prevent fraud
Consumer Reporting Agencies: Credit reports and consumer reports (with your authorization and for permissible purposes under the Fair Credit Reporting Act)
Data Analytics Providers: To enhance our understanding of client needs and improve our services
Background Check Services: For compliance and due diligence purposes
Fraud Prevention Services: To detect and prevent fraudulent activity

4.7 From Public Sources

We may obtain information from publicly available sources, including:

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Public records (property records, business registrations, court records)
News articles and publications
Databases and registries

4.8 From Referral Sources

We may receive your contact information from:

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Existing clients who refer you to us (with their understanding that you have consented)
Professional referral networks and strategic partners
Marketing partners and business development sources

5. HOW WE USE YOUR INFORMATION

We use your personal information for the following business and operational purposes:

5.1 Providing Investment Advisory Services

Opening and maintaining your investment advisory accounts
Providing personalized investment advice and portfolio management
Conducting financial planning and analysis
Developing and implementing investment strategies tailored to your objectives
Executing securities transactions on your behalf
Monitoring and rebalancing your investment portfolios
Providing ongoing account management and client service

5.2 Servicing Your Account

Responding to your inquiries, questions, and requests
Providing customer service and technical support
Processing transactions, payments, and account changes
Generating and delivering account statements, confirmations, and reports
Providing tax reporting documents and year-end summaries
Communicating with you about your account and our services

5.3 Regulatory Compliance and Legal Obligations

SEC and State Registration Requirements: Complying with our obligations as a registered investment adviser, including maintaining required books and records
Anti-Money Laundering (AML) Compliance: Verifying your identity and conducting customer due diligence to prevent money laundering and terrorist financing
Know Your Customer (KYC) Requirements: Collecting and verifying information to understand your financial situation and investment objectives
Tax Reporting: Preparing and filing required tax reports with federal and state authorities
Legal Process: Responding to subpoenas, court orders, legal process, and government inquiries
Regulatory Examinations: Cooperating with SEC, state, and other regulatory examinations and audits
Recordkeeping: Maintaining records as required by SEC Rule 204-2 and other applicable regulations

5.4 Risk Management and Security

Detecting, preventing, and investigating fraud, money laundering, and other illegal activities
Monitoring account activity for suspicious or unauthorized transactions
Protecting against security threats, cyberattacks, and unauthorized access
Conducting risk assessments and implementing risk mitigation measures
Maintaining the security and integrity of our systems and your information
Conducting internal audits and compliance reviews
Implementing our incident response program under Regulation S-P

5.5 Business Operations and Analysis

Processing and fulfilling transactions and service requests
Managing relationships with service providers and vendors
Analyzing data to improve our services and develop new offerings
Conducting market research and understanding client needs
Evaluating the effectiveness of our advisory strategies
Performing internal business administration and operations
Training our employees and maintaining quality assurance

5.6 Communications and Marketing

Communicating with you about your account, services, and our firm
Sending educational content, market updates, and investment insights
Informing you about products, services, and events that may interest you
Sending newsletters, publications, and thought leadership content
Marketing our investment advisory services to prospective clients
Obtaining your feedback through surveys and questionnaires
Personalizing your experience with our firm

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You may opt out of receiving marketing communications at any time by following the unsubscribe instructions in our emails, contacting us at the information provided in Section 14, or adjusting your communication preferences through your account settings.

5.7 Coordinating with Your Other Advisors

With your consent or at your direction, we share information with your other professional advisors, such as:

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Attorneys for estate planning and legal matters
CPAs and tax preparers for tax planning and preparation
Insurance agents for insurance planning and implementation
Other financial advisors when coordinating comprehensive financial strategies

5.8 Website and Technology Functions

Operating and maintaining our website, client portal, and mobile applications
Authenticating your identity and providing secure access
Delivering requested features and functionality
Analyzing website usage to improve performance and user experience
Troubleshooting technical issues and providing technical support
Detecting and preventing fraudulent use of our digital services

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We may share your personal information in the following circumstances. We do not sell your personal information to anyone, for any reason, at any time.

We may potentially share your personal information with our affiliated entities for business purposes, including:

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Coordinated Services: To provide services you request from multiple affiliated entities
Referrals: To facilitate referrals among affiliated companies
Business Operations: To conduct consolidated business operations, risk management, and compliance functions
Group Services: To provide centralized services such as information technology, legal, compliance, and human resources

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Affiliate Marketing Opt-Out: Under federal law, you have the right to opt out of our affiliated entities using your information to market their products and services to you. If you wish to exercise this right, please contact us using the information in Section 14.

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California Residents: For California residents who are existing clients, the GLBA exemption applies to information we collect in connection with providing financial services, and such information is exempt from the CCPA's affiliate sharing restrictions. For prospective clients and website visitors who are California residents, you have rights under the CCPA regarding affiliate sharing as described in Section 8 below.

We share your information with service providers and vendors who perform services on our behalf, including:

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Custodians and Broker-Dealers: To hold your assets and execute transactions
Account Aggregation Services: To collect information about your accounts held at other institutions (with your authorization)
Technology Providers: For client relationship management (CRM) systems, portfolio management software, performance reporting tools, and cybersecurity services
Cloud Service Providers: For secure data storage and computing services
Administrative Service Providers: For recordkeeping, document management, and proxy voting services
Professional Service Providers: Legal counsel, auditors, consultants, and compliance professionals
Identity Verification and Fraud Prevention Services: To verify your identity and prevent fraud
Communication Services: Email service providers, mail processing services, and customer communication platforms

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Service Provider Requirements: We require all service providers to:

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Implement appropriate administrative, technical, and physical safeguards to protect your information
Use your information only for the specific purposes for which we engage them
Notify us within 72 hours if they become aware of unauthorized access to or use of your information
Comply with applicable privacy and security laws

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We conduct due diligence before engaging service providers and perform ongoing oversight to ensure they maintain appropriate safeguards for your information.

We share your information when you have provided consent or directed us to do so, including:

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Sharing information with your spouse, family members, or other designated individuals
Coordinating with your other professional advisors as described in Section 5.7
Fulfilling specific requests you make to share information with third parties
Providing information to joint account holders and authorized representatives

We may disclose your information when required or permitted by law, including:

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Legal Compliance: To comply with applicable laws, regulations, and legal obligations
Regulatory Requests: In response to requests from the SEC, state securities regulators, FINRA, or other regulatory authorities
Legal Process: Pursuant to subpoenas, court orders, warrants, or other legal process
Law Enforcement: To cooperate with law enforcement investigations
Protection of Rights: To protect our rights, property, safety, or the rights, property, and safety of our clients, employees, or others
Fraud Prevention: To detect, prevent, and investigate fraud, money laundering, and other illegal activities

We may share your information in connection with a corporate transaction, including:

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Merger, acquisition, or sale of assets
Corporate reorganization or restructuring
Bankruptcy or insolvency proceedings
Due diligence related to any of the above

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In such cases, we will require the acquiring or successor entity to honor the commitments made in this Privacy Policy.

6.6 Exceptions Under Federal Law

Under the Gramm-Leach-Bliley Act and its implementing regulations, we may share your nonpublic personal information with nonaffiliated third parties without providing you an opportunity to opt out in the following circumstances:

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As necessary to effect, administer, or enforce a transaction you request or authorize
To maintain or service your account
In connection with processing or servicing a financial product or service you request
In connection with maintaining or servicing your account with us or with another entity as part of a private label credit card program or similar extension of credit
To resolve consumer disputes or inquiries
To comply with federal, state, or local laws, rules, and legal requirements
To comply with a properly authorized civil, criminal, or regulatory investigation or subpoena
To report to consumer reporting agencies
To report to government entities for fraud prevention purposes
For institutional risk control or resolving customer disputes
To protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability
For required institutional risk control or for resolving customer disputes or inquiries
To protect the confidentiality or security of our records

6.7 Aggregate and De-Identified Information

We may share aggregate, de-identified, or anonymized information that does not identify you personally for research, analysis, marketing, and other business purposes. Such information is not considered personal information under applicable privacy laws.

6.8 What We Do Not Do With Your Information

To emphasize our commitment to your privacy:

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We do not sell your personal information to anyone, for any reason, at any time
We do not rent or lease your personal information to third parties for their marketing purposes
We do not share your information with nonaffiliated third parties for marketing purposes unless you have provided consent (California residents must provide opt-in consent under state law)
We do not share your account numbers with nonaffiliated third parties for marketing purposes

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7. YOUR PRIVACY RIGHTS AND CHOICES

7.1 Opt-Out Rights Under Federal Law

Nonaffiliated Third-Party Sharing: Federal law generally requires that we provide you with the opportunity to opt out before we share your nonpublic personal information with nonaffiliated third parties, except as permitted by law (see Section 6.6). Currently, we do not share your information with nonaffiliated third parties for marketing purposes outside the permissible exceptions.

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Affiliate Marketing: You have the right to opt out of our affiliated entities using your information (such as information about your creditworthiness) to market their products and services to you. To exercise this opt-out right, contact us using the information in Section 14.

7.2 Annual Privacy Notice Exception

Under federal law, financial institutions that meet certain conditions are not required to provide annual privacy notices to customers. Advisors qualifies for this exception because we:

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Share nonpublic personal information only under the exceptions permitted by Sections 13, 14, and 15 of Regulation S-P
Have not changed our policies and practices regarding disclosure of nonpublic personal information from those most recently disclosed to you

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If our practices change such that we no longer qualify for this exception, we will provide you with an updated privacy notice before implementing the change.

7.3 Communication Preferences

Marketing Communications: You may opt out of receiving marketing emails, newsletters, and promotional communications from us at any time by:

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Clicking the "unsubscribe" link at the bottom of our marketing emails
Contacting us at privacy@farther.com
Adjusting your communication preferences in your account settings

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Important Account Communications: Even if you opt out of marketing communications, we will continue to send you important account-related communications, such as account statements, confirmations, tax documents, regulatory notices, and service-related announcements.

7.4 Accessing and Updating Your Information

You may access and update your personal information by:

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Logging into your secure client portal
Contacting your dedicated financial advisor
Emailing us at privacy@farther.com
Sending mail to Farther Finance Advisors, LLC, Attention: Privacy Officer, [345 California St, Ste 600, San Francisco, CA 94104]

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We encourage you to keep your information current and accurate. Please notify us promptly of any changes to your contact information, financial circumstances, investment objectives, or other material information that may affect our advisory relationship.

7.5 Credit Report Rights

Obtaining Consumer Reports: We may obtain consumer reports about you from consumer reporting agencies (such as credit reports) for permissible purposes under the Fair Credit Reporting Act, including to verify information you provide and to evaluate applications for financial products and services.

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Adverse Action Notices: If we take adverse action based in whole or in part on information contained in a consumer report, we will provide you with written notice that includes:

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The name, address, and telephone number of the consumer reporting agency that provided the report
A statement that the consumer reporting agency did not make the adverse decision and cannot explain why the decision was made
Your right to obtain a free copy of your consumer report from the agency within 60 days
Your right to dispute the accuracy or completeness of information in the report

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Free Annual Credit Reports: You have the right to obtain a free credit report once every 12 months from each of the three nationwide consumer reporting agencies (Equifax, Experian, and TransUnion) by visiting www.annualcreditreport.com or calling 1-877-322-8228.

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8. CALIFORNIA PRIVACY RIGHTS

This section applies to California residents and describes rights provided under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and other California privacy laws.

8.1 Application of the CCPA to Farther

GLBA Exemption: The CCPA provides a limited exemption for personal information that is collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (GLBA), 15 U.S.C. § 6801 et seq., and its implementing regulations. As a registered investment adviser, Advisors is subject to GLBA. However, this exemption is activity-based and purpose-specific, not a blanket exemption for all information about our clients.

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Understanding the Scope of the GLBA Exemption:

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The GLBA exemption applies only to personal information that we collect, process, or disclose for purposes directly related to:

- Providing financial products or services to you as required or authorized under GLBA

- Activities necessary to effect, administer, or enforce transactions you request or authorize

- Maintaining or servicing your account with us

- Complying with GLBA's own privacy, safeguarding, and regulatory requirements

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The GLBA exemption does NOT apply to personal information we collect or use for purposes outside the scope of GLBA, including but not limited to:

- Marketing and advertising activities (except as specifically permitted under GLBA)

- Website analytics and user experience optimization

- General business operations not directly related to providing financial services

- Employment-related decisions or background checks

- Social media interactions and engagement - Market research and product development

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Application to Different User Categories:

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Existing Clients (Customers): If you are an existing client with an ongoing advisory relationship with Farther Finance Advisors:

- Personal information we collect and use pursuant to GLBA for providing investment advisory services, maintaining your account, and complying with financial services regulations is generally exempt from the CCPA under the GLBA exemption.

- However, personal information we collect or use for purposes outside the scope of GLBA (such as website browsing behavior, marketing preferences, or information collected through cookies for advertising purposes) remains subject to the CCPA, and you retain CCPA rights with respect to such information.

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Prospective Clients: If you are a prospective client who has inquired about our services or submitted information through our website but have not yet entered into an advisory agreement:

- The information we collect about you before you become a customer is generally not covered by the GLBA exemption because we do not yet have a customer relationship with you for purposes of providing financial services.

- Therefore, if you are a California resident, such information is subject to the CCPA, and you have the full range of rights described in Section 8.2 below.

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Website Visitors: If you visit our website without providing personal information or establishing a business relationship:

- Information collected through cookies, analytics, and similar technologies is subject to the CCPA (for California residents) because it is not collected pursuant to GLBA.

- You have the rights described in Section 8.2 below, including the right to opt out of the sale or sharing of your personal information.

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Important Note About Mixed-Purpose Information:

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Some personal information may be collected or used for both GLBA-covered purposes and non-GLBA purposes. For example:

- Your email address may be used both to send you account statements (GLBA-covered) and marketing newsletters (not GLBA-covered)

- Your browsing activity on our client portal may be used both to provide secure account access (GLBA-covered) and to analyze user experience for marketing purposes (not GLBA-covered)

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When information is used for mixed purposes, the GLBA exemption applies only to the GLBA-covered uses. For non-GLBA uses, California residents retain their CCPA rights.

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Transition from Prospective Client to Customer:

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Once you become a customer by entering into an investment advisory agreement:

- Information we collect going forward in connection with providing financial services pursuant to GLBA becomes subject to the GLBA exemption (to the extent used for GLBA-covered purposes)

- Information collected before you became a customer may continue to be subject to CCPA for its original collection purposes

- Information collected or used for non-GLBA purposes after you become a customer remains subject to CCPA

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If you have questions about whether specific information or uses are covered by the GLBA exemption, please contact our Privacy Officer at privacy@farther.com.

8.2 California Consumer Rights

If you are a California resident and your information is not subject to the GLBA exemption (e.g., you are a prospective client or website visitor), you have the following rights under the CCPA:

Right to Know

You have the right to request that we disclose to you:

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The categories of personal information we have collected about you
The categories of sources from which the personal information was collected
The business or commercial purposes for collecting, selling, or sharing personal information
The categories of third parties to whom we disclose personal information
The specific pieces of personal information we have collected about you

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You may submit a request to know up to twice in a 12-month period.

Right to Delete

You have the right to request that we delete personal information we have collected from you, subject to certain exceptions. We may retain personal information as necessary to:

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Complete the transaction for which the information was collected, provide a service you requested, or perform under a contract with you
Detect and resolve security incidents and protect against malicious, deceptive, fraudulent, or illegal activity
Debug to identify and repair errors
Comply with legal obligations
Use the information internally in ways that are compatible with the context in which you provided it or that are reasonably aligned with your expectations

Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you. We will use commercially reasonable efforts to correct the information as directed by you.

Right to Opt-Out of Sale or Sharing

You have the right to opt out of the "sale" or "sharing" of your personal information. Under the CCPA:

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"Selling" means disclosing personal information to a third party for monetary or other valuable consideration
"Sharing" means disclosing personal information to a third party for cross-context behavioral advertising (also known as targeted advertising)

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Our Practice: We do not sell your personal information in exchange for money. However,

when you visit our website, we may disclose certain categories of personal information to

third-party advertising and analytics partners through cookies and similar technologies. Under

the CCPA, these disclosures may be considered a "sale" or "sharing" of personal information

even though we do not receive monetary compensation.

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Specific Information That May Be "Sold" or "Shared":

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The following table describes the categories of personal information we may disclose in ways

that could constitute "sale" or "sharing" under the CCPA, the purposes for such disclosures,

and the categories of third parties who may receive the information: