PRIVACY POLICY
AVL Advisory LLC (“AVL Advisory,” “we,” “us,” or “our”) respects the privacy of our clients and is committed to protecting the confidentiality and security of the nonpublic personal information entrusted to us. We provide this notice to describe how we collect, use, share, and safeguard your information, consistent with the Gramm-Leach-Bliley Act (GLBA), applicable state investment adviser privacy regulations, and the privacy and safeguarding standards modeled on the U.S. Securities and Exchange Commission’s Regulation S-P.
In the course of providing financial planning, investment advisory, tax planning, and related advisory services, we collect personal and financial information necessary to serve our clients, meet our legal and regulatory obligations, and operate our business responsibly. We are required by law to deliver this notice to clients at the start of our advisory relationship and to make it available thereafter. We will notify you of our privacy practices at least annually if and as required by applicable law, and whenever this policy is revised in a manner that materially affects your rights.
Information We Collect
We may collect nonpublic personal information about you from the following sources:
Information you provide to us directly, including through questionnaires, applications, advisory agreements, financial planning documents, tax documents, emails, meetings, secure portals, or other communications.
Information about your financial circumstances, including your income, assets, liabilities, investment accounts, retirement accounts, tax situation, estate planning documents, insurance coverage, employment information, family financial information, and other matters relevant to the services we provide.
Information about your transactions or accounts with us, custodians, financial institutions, or other service providers.
Information from third parties with your authorization, including custodians, broker-dealers, accountants, attorneys, insurance professionals, payroll providers, employers, trustees, executors, or other advisers.
Information We Disclose
We do not sell client information. We do not disclose nonpublic personal information about current or former clients except as permitted or required by law, as necessary to provide services, or as authorized by the client.
We may disclose nonpublic personal information to nonaffiliated third parties in limited circumstances, including custodians, broker-dealers, financial planning software providers, tax software providers, billing providers, client portal providers, document storage providers, compliance consultants, attorneys, accountants, auditors, regulators, and other service providers necessary to support our advisory business.
We may also disclose information to professionals or institutions you authorize us to communicate with, such as your CPA, attorney, insurance agent, banker, employer, trustee, executor, or other adviser.
We may disclose information when required or permitted by law, including in response to regulatory requests, court orders, subpoenas, legal proceedings, audits, examinations, or other lawful requests.
Information Sharing and Opt-Out Rights
AVL Advisory LLC does not share nonpublic personal information with nonaffiliated third parties for those third parties’ own independent marketing purposes.
Because we limit our sharing to purposes permitted by law—such as servicing client accounts, processing transactions, maintaining records, complying with legal and regulatory obligations, and providing the services you have requested—there is generally no opt-out right required for these disclosures under federal or applicable state privacy law.
If our information-sharing practices change in a manner that would require us to offer an opt-out right, we will provide you with a revised notice and a reasonable opportunity to opt out before making any such disclosure.
How We Protect Your Information
We maintain physical, electronic, and procedural safeguards reasonably designed to protect client information and to ensure its confidentiality, integrity, and security. These safeguards may include secure client portals, password protection, multi-factor authentication, access controls, encryption where appropriate, secure document storage, vendor due diligence, employee confidentiality obligations, cybersecurity practices, and limitations on access to client information.
We restrict access to nonpublic personal information to personnel, service providers, and professionals who need the information to provide services, operate our business, or comply with legal and regulatory obligations. We maintain written policies and procedures reasonably designed to safeguard client records and information.
Service Providers and Vendor Oversight
We may share information with service providers that assist us in operating our business and providing services to clients. Before engaging service providers that receive access to nonpublic personal information, we conduct due diligence and obtain reasonable assurances that they are capable of maintaining appropriate safeguards. These providers are expected to maintain safeguards reasonably designed to protect client information, to use such information only for the purposes for which it was provided, and to notify us promptly in the event of a breach affecting client information.
Data Security Incidents and Breach Notification
We maintain a written incident response program reasonably designed to detect, respond to, and recover from unauthorized access to or use of client information. In the event we determine that sensitive client information has been, or is reasonably likely to have been, accessed or used without authorization, we will take appropriate steps to assess, contain, and remediate the incident.
Where required by applicable law, we will notify affected individuals as soon as practicable, and in no event later than 30 days after we become aware that such an incident has occurred or is reasonably likely to have occurred. Our notice will include, to the extent known, a description of the incident, the type of information involved, and steps affected individuals may consider taking to protect themselves.
Former Clients
If you are no longer a client of AVL Advisory LLC, we will continue to protect your nonpublic personal information as described in this Privacy Policy. We retain and disclose information about former clients only as permitted or required by law and consistent with our recordkeeping obligations.
Website Privacy
When you visit our website, we may collect limited technical information, such as IP address, browser type, device information, pages visited, and general usage data. We may use this information to maintain website functionality, improve user experience, monitor website performance, and protect against misuse.
Our website may contain links to third-party websites. We are not responsible for the privacy practices, content, or security of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.
Submitting information through our website does not, by itself, create an advisory relationship with AVL Advisory LLC.
Changes to This Privacy Policy
We reserve the right to amend this Privacy Policy at any time. If we make material changes to our privacy practices, we will provide you with a revised notice as required by applicable law. The most current version of this Privacy Policy will govern our use of your information.
Questions and Contact Information
If you have questions about this Privacy Policy or how we handle your information, please contact:
AVL Advisory LLC
128 Orange Ave
Daytona Beach, FL 32114
Phone: 386-334-9765
Email: alupoli@avladvisory.com