Privacy Policy

Introduction

This privacy policy (“Privacy Policy”) describes the ways Clute Wealth Management, LLC, and its affiliates and subsidiaries (“We”, “Us”, or “Clute Wealth Management”) collect, store, use, disclose, and protect your personal information. We use the term “personal information” to describe information that can be associated with you and can be used to identify you. Personal information does not include information that does not identify a specific person. You agree to the practices regarding your personal information described in this Privacy Policy when you use LPL Financial Account View Site or other LPL Financial online services (collectively, the “LPL Financial online services”).

Information We Collect

When you use online services, we may collect certain information relating to that use, some of which may be personal information. Examples of personal information include your name, address, telephone number, email address, other means to contact you, and Social Security number, as well as other information you may supply us in connection with a financial product or service, such as your demographic information, investment preferences, location information, or financial information. In addition, we may collect information such as your Internet Protocol (IP) address and/or domain, the type and version of your Internet browser software and operating system you use, the date, time, and duration of your online services access, the specific pages, buttons, images, links, and forms that you access while visiting Clute Wealth Management online services, the type of device you use to access Clute Wealth Management online services (such as a BlackBerry, iPhone, or iPad), your mobile carrier and/or Internet Service Provider. Collection of this data does not personally identify you. We may also use third party applications and services to collect and analyze this information in the aggregate. We may also collect information about you that you otherwise submit to us, such as through email and other means.

Users of the Clute Wealth Management online services may have the option to authenticate their identity using biometric recognition capabilities on their devices. When users of the Clute Wealth Management online services enable biometric identification, Clute Wealth Management does not collect or receive biometric information or biometric identifiers.

Our Use of Personal Information

We may use your personal information to (i) provide information, products or services you request in Clute Wealth Management online services; (ii) verify your identity when accessing these services; (iii) enforce our Terms of Use and any other agreements between you and Clute Wealth Management; (iv) improve, modify, customize, and measure Clute Wealth Management online services; (v) provide you with information about Clute Wealth Management products and services while you are on the Clute Wealth Management online services or after you visit the Clute Wealth Management online services; (vi) compare information for accuracy and verify our records; (vii) detect and prevent fraud or other criminal activities; or (viii) in other ways allowed by law.

Sharing Personal Information in Connection with Clute Wealth Management Online Services

To provide Clute Wealth Management online services, we may share some of your personal information with other entities who perform services for Clute Wealth Management. We may share your personal information with service providers who are authorized to use your personal information only as necessary to support our business operations, such as those who provide data storage, payment, technology support and services, customer service, risk solution provision, analytics, fraud prevention, and marketing services. We may also share some of your personal information as otherwise permitted or required by law or as authorized by you.

If you are a Vermont client, you must affirmatively opt-in prior to disclosure by Clute Wealth Management of any non-public personal information to non-affiliated third parties (other than as permitted by law). The opt-in consent must be in writing or, if you agree, in electronic form. However, Clute Wealth Management may disclose your non-public personal information to non-affiliated financial institutions with whom we have a business arrangement for proper business purposes in connection with providing you with financial planning services.

Updating and Correcting Your Personal Information

Keeping your information accurate and up to date is very important. If your personal or account information is incomplete, inaccurate or not current, please contact your Clute Wealth Management financial advisor at (877) 561-5707.

Cookies and Similar Technology

When you access Clute Wealth Management online services, we, or third parties we hire to track how our website is used, may place small data files called “cookies” on your browser or other access device. Cookies are pieces of data stored on your device and are assigned by a web server to the browser on your device. When you return to a site you have visited before, your browser gives this data back to the server.

A “session cookie” may be sent to your computer or other access device when you log in to Clute Wealth Management online services. This type of cookie recognizes you if you visit multiple pages on a site during the same session, so that you do not need to be prompted for your password on each page. Once you log out or close your browser, this cookie expires and no longer has any effect. “Persistent” or longer-lasting cookies can be used for other purposes, such as to record user experience preferences when you use a website and to inform you about Clute Wealth Management products and services during and after you visit the Clute Wealth Management online services, a process known as remarketing. These cookies do not expire once you log out or close your browser. You are free to decline our cookies if your browser permits but doing so may interfere with your use of Clute Wealth Management online services.

Clute Wealth Management and the third parties who assist in operating Clute Wealth Management online services do not respond differently or limit their practices under the terms of this policy when you access those online services with a browser that uses a do not track signal or similar mechanism.

Storage and Protection of Personal Information

We maintain administrative, technical, and physical safeguards that are designed to protect the privacy and security of personal information. In order to help secure personal information collected from you as a Clute Wealth Management online services user, including sensitive financial data, the information is protected by SSL encryption when it is exchanged between your web browser and Clute Wealth Management online services. However, the internet is not a fully secure environment, and we cannot ensure or warranty the security of any information transmitted to or generated by Clute Wealth Management in connection with Clute Wealth Management's online services. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, technical, and physical, or other operational, safeguards. You play a critical role in protecting your information by maintaining up-to-date computer security protections. Steps you take to ensure the security of your computer, computer passwords, or other personal identifier authentication mechanisms are key components of the protection of your personal information. You agree that you are responsible for any additional verification procedures and security you deem necessary.

By using Clute Wealth Management online services, you agree that the procedures provided for in this Privacy Policy and the procedures implemented on Clute Wealth Management online services to protect personal information and to verify the identity of Clute Wealth Management online services users including, but not limited to, those procedures described in the foregoing paragraph, constitute commercially reasonable website security and customer verification procedures.

Suspicious Email

It is our policy not to email you or send you electronic communications to request non- public personal information or account information (such as a username or password). If you receive an unsolicited email or other electronic communication that appears to be from Clute Wealth Management but you suspect may be from another source and might be fraudulent, please email us at cwm@clutewealthmanagement.com.

Social Media

You may also find additional information on our products and services through our social media sites such as Facebook, LinkedIn, or Twitter. Please keep in mind that any information you share is visible to all participants on these social media sites and you should never post any sensitive personal information (such as account number or tax identification). Please carefully review the Terms of Use and Privacy Policy on these social media sites as they may be different than our own policies.

Personal Information on Children

We respect the privacy of children and encourage all parents to supervise their children’s computer usage. We do not intend to invite children to visit Clute Wealth Management online services and we do not knowingly collect or retain personal information from children under the age of thirteen (13). For more information on the Children’s Online Privacy Protection Act (COPPA), please visit the Federal Trade Commission website at www.ftc.gov.

Notice to Persons Accessing the Clute Wealth Management Site Outside the United States

If you access the Clute Wealth Management online services outside the United States, any information you provide to us through the Clute Wealth Management online services will be transferred out of that jurisdiction and into the United States. If you do not want your personally identifiable information to leave that jurisdiction, do not provide the information to us. By providing personally identifiable information to us, you explicitly consent to the transfer of your information to the United States.

Contacting Us About Privacy Questions

If you have questions or concerns regarding this Privacy Policy, you should contact us by email at cwm@clutewealthmanagement.com.

Changes to this Privacy Policy

This Privacy Policy is subject to change. Please review it periodically. If we make changes to the Privacy Policy, we will revise the “Last Updated” date at the bottom of this Policy. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the site. Your use of Clute Wealth Management online services following these changes means that you accept the revised Privacy Policy.

Last updated August 2023.