Privacy Policy

We gather information about you so that we can:

• Help design and implement the investment and planning related services we provide you; and
• Comply with the Federal and State laws and regulations that govern us.

We may collect the following types of "nonpublic personal information" about you:

• Information from our initial meeting or subsequent consultations about your identity, such as your name, address, social security number, date of birth, and financial information.
• Information that we generate to service your financial needs.
• Information that we may receive from third parties with respect to your financial profile.

We are permitted by law to disclose nonpublic information about you to unaffiliated third parties in certain circumstances. GW may disclose client's information:

• to individuals and/or entities not affiliated with GW, including, but not limited to certain service providers (i.e., broker-dealer, subadvisers, account custodian, record keeper, etc.) in furtherance of the client's engagement with GW to service your account;
• to your authorized representative or power of attorney; or
• otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.

Since GW shares nonpublic information solely to service client accounts, the firm does not disclose any nonpublic personal information about the firm's customers or former customers to anyone, except as permitted by law. In the event that the firm has a change to its client privacy policy that would allow it to disclose non-public information not covered under applicable law, the firm will allow its clients the opportunity to opt-out of such disclosure.

Privacy has always been important to GW. We restrict and limit access to client information only to those who need to carry out their business functions. We safeguard client information by preventing its unauthorized access, disclosure, or use. We maintain physical, electronic, and procedural safeguards to protect your confidential personal information. Arrangements with companies or independent contractors not affiliated with GW will be subject to confidentiality agreements.

Our portal integrates with the following third-party services:

• Plaid: For secure bank account connectivity and transaction data
• Supabase: For secure data storage and authentication
• Custodial Partners: For account and investment data

These services have their own privacy policies and security measures. We carefully vet all third-party providers to ensure they meet our security standards.

We protect your information through:

• Bank-level encryption for data transmission and storage
• Multi-factor authentication for account access
• Regular security audits and monitoring
• Restricted access to personal information on a need-to-know basis
• Secure disposal of information when no longer needed

You have the right to:

• Access and review your personal information
• Request corrections to inaccurate information
• Opt out of certain communications
• Request deletion of your information (subject to legal requirements)
• Receive a copy of this Privacy Policy annually

In the unlikely event of a data breach that affects your personal information, we will notify you promptly in accordance with applicable laws and regulations, including Minnesota state requirements.

Even if we cease to provide you with financial services, our Privacy Policy will continue to apply to you, and we will continue to treat your nonpublic information with strict confidentiality.