Effective Date: [DATE]
This Privacy Policy explains how Advisor Marketers (“we,” “us,” or “our”) collects, uses, shares, and protects personal information when you use our websites, marketing services, software platform (Advisor Command™), and other services (collectively, “our Services”).
We are committed to handling your personal information responsibly and in accordance with applicable privacy laws, including Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), British Columbia’s Personal Information Protection Act (PIPA), Canada’s Anti-Spam Legislation (CASL), the U.S. California Consumer Privacy Act (CCPA/CPRA), and other applicable laws.
By using our Services, you agree to the collection, use, and sharing of your information as described in this Policy.
1. Who This Policy Applies To
This Policy applies to two categories of users:
Business Users — financial professionals, advisors, agencies, and businesses who subscribe to Advisor Command™ or our other B2B services.
Consumer Users — individuals who interact with our consumer-facing marketing websites, landing pages, contact forms, and lead-generation services.
Some provisions apply only to one category; these are identified accordingly.
2. Information We Collect
2.1 Information you provide directly. This includes:
- Identity information: first and last name, date of birth, gender
- Contact information: email address, phone number, mailing address, city, province/state, postal/ZIP code, country
- Business information (Business Users): business name, role, website URL
- Financial context information (Consumer Users): age range, general retirement asset range, retirement goals, areas of concern, marital and household status as it relates to retirement planning
- Communication preferences and consent records
- Information you voluntarily provide in form submissions, calls, emails, or messages
- Photographs you submit or that we take at events you attend
2.2 Information collected automatically. When you visit our Services, we automatically collect:
- IP address and approximate geographic location
- Browser type, browser version, operating system, and device identifiers
- Pages visited, time spent on pages, click patterns, and referring URLs
- Date and time of visits
- Cookies and similar tracking technologies (see Section 7)
2.3 Information from third parties. We may receive information about you from:
- Marketing partners and advertising platforms
- Public databases and verification services
- Licensed financial professionals who confirm their interactions with you
2.4 Sensitive information. We do not intentionally collect government identifiers (SSN, SIN), health information, or financial account numbers through our Consumer Services. If you submit such information unprompted, we will treat it with appropriate care but recommend you not share it.
3. How We Use Your Information
We use personal information for the following purposes:
For Consumer Users:
- To review and respond to your request for a consultation
- To match you with an appropriate licensed financial professional
- To facilitate communication between you and that professional
- To send you appointment confirmations, reminders, and follow-up communications
- To improve our matching process and service quality
For Business Users:
- To create and maintain your account
- To process payments and renewals
- To deliver the services you’ve subscribed to
- To provide customer support
For all users:
- To send marketing communications (where you’ve consented)
- To analyze usage patterns and improve our Services
- To prevent fraud, abuse, and security incidents
- To comply with legal obligations
- To enforce our Terms of Service
4. How We Share Your Information
4.1 With licensed financial professionals (Consumer Users only). When you submit a request through our Consumer Services, we share your information with one or more independent licensed financial professionals who may contact you regarding your request. This sharing is the core purpose of our Consumer Services. By submitting your information, you authorize this sharing. Once your information is shared with a licensed professional, that professional becomes responsible for handling your data under their own privacy practices, separate from this Policy.
4.2 With service providers. We share information with third-party service providers who help us operate our business, including:
- Cloud hosting and infrastructure providers
- Email and SMS delivery services
- Payment processors (Stripe, PayPal)
- Analytics providers (Google Analytics)
- Advertising and remarketing platforms (Google, Meta/Facebook, X/Twitter, LinkedIn)
- Customer support tools
- Software platform partners (including HighLevel, which underlies Advisor Command™)
These providers are contractually required to use your information only to provide services to us.
4.3 With marketing partners. Some of our marketing activities are conducted with or through independent third-party marketing vendors. We may share information with these vendors as necessary to operate joint marketing activities.
4.4 For legal and safety reasons. We may disclose information when we believe in good faith it is necessary to:
- Comply with applicable law, regulation, legal process, or government request
- Protect the rights, property, or safety of Advisor Marketers, our users, or the public
- Investigate or prevent fraud, abuse, or illegal activity
- Enforce our Terms of Service or other agreements
4.5 Business transfers. If Advisor Marketers is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a different privacy policy.
4.6 Sale of personal information. We do not sell personal information for monetary consideration. However, our sharing of personal information with licensed financial professionals, who provide us with marketing fees, may be considered a “sale” or “sharing” under certain U.S. state privacy laws (including the CCPA/CPRA). California and other U.S. state residents have the right to opt out of this sharing — see Section 10.
5. Communications and Marketing Consent
5.1 Express consent (CASL compliance). Before sending you commercial electronic messages (email or SMS) for marketing purposes, we will obtain your express consent in accordance with Canada’s Anti-Spam Legislation (CASL).
5.2 Communications related to your inquiry. When you submit a request through our Consumer Services, you consent to being contacted by Advisor Marketers, our marketing partners, and licensed financial professionals via phone, email, and SMS regarding that inquiry. Standard messaging rates may apply.
5.3 Unsubscribe. You may opt out of marketing communications at any time by:
- Clicking the unsubscribe link in any email
- Replying STOP to any text message
- Contacting us directly at the email address below
Opt-out requests will be processed within 10 business days, as required by CASL.
5.4 Transactional communications. You cannot opt out of certain transactional or service-related communications (e.g., appointment confirmations, account notifications) while you continue to use our Services.
6. Data Retention
We retain personal information only as long as necessary for the purposes described in this Policy or as required by law. Specific retention guidelines:
- Consumer User request information: Retained for 24 months after the last interaction, unless a longer period is required by law or by an active relationship with a licensed financial professional.
- Business User account data: Retained for the duration of the subscription and for 7 years thereafter for tax and legal compliance.
- Marketing consent records: Retained for 36 months after consent is withdrawn, to demonstrate compliance with applicable laws.
- Usage data and analytics: Retained in aggregated form indefinitely; in personally identifiable form, typically for 14 months.
- Communications records (call recordings, email exchanges): Retained for 36 months unless a longer period is required.
After the applicable retention period, we securely delete or anonymize the information.
7. Cookies and Tracking Technologies
We use cookies, web beacons, and similar tracking technologies to operate our Services, analyze usage, and deliver marketing. Categories of cookies we use:
- Strictly necessary cookies — required for the Services to function
- Analytics cookies — help us understand how our Services are used
- Marketing cookies — used for advertising and remarketing across other websites
- Preference cookies — remember your settings and preferences
You can manage cookie preferences through your browser settings or through our cookie consent banner (where available). Disabling certain cookies may limit functionality.
Do Not Track signals. We do not currently respond to “Do Not Track” browser signals.
8. Third-Party Analytics and Advertising
We use the following third-party analytics and advertising services. You can opt out of each directly through the links provided:
- Google Analytics — https://tools.google.com/dlpage/gaoptout
- Google Ads remarketing — https://www.google.com/settings/ads
- Meta (Facebook) advertising — https://www.facebook.com/help/568137493302217
- X (Twitter) advertising — https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
- Digital Advertising Alliance (U.S.) — https://www.aboutads.info/choices/
- Digital Advertising Alliance of Canada — https://youradchoices.ca/
9. Your Privacy Rights
Depending on where you live, you may have certain rights regarding your personal information:
9.1 Canadian residents (PIPEDA / BC PIPA / provincial privacy laws):
- Access to your personal information
- Correction of inaccurate information
- Withdrawal of consent (subject to legal and contractual restrictions)
- Complaint to the Office of the Privacy Commissioner of Canada or your provincial commissioner
9.2 California residents (CCPA/CPRA):
- Right to know what personal information we collect and how we use it
- Right to access and request deletion of your personal information
- Right to correct inaccurate personal information
- Right to opt out of “sale” or “sharing” of personal information
- Right to limit use of sensitive personal information
- Right not to be discriminated against for exercising these rights
9.3 Other U.S. state residents (Virginia, Colorado, Connecticut, Utah, Texas, and others): You may have similar rights to access, correct, delete, and opt out of certain processing of your personal information.
9.4 European Economic Area, UK, and similar jurisdictions: If applicable, GDPR/UK GDPR rights including access, rectification, erasure, restriction, portability, and objection.
To exercise any of these rights, contact us at [email protected]. We will respond within the timeframes required by applicable law (typically 30-45 days). We may need to verify your identity before processing your request.
10. Opting Out of Sharing
To opt out of the sharing of your personal information with licensed financial professionals or marketing partners, you may:
- Contact us at [email protected] with the subject “Opt Out of Sharing”
- Use the opt-out link (where provided) on our Services
- Update your communication preferences in your account (Business Users)
Note that opting out of sharing with licensed financial professionals will prevent us from fulfilling the core purpose of our Consumer Services (connecting you with a professional). If you do not wish to be connected with a licensed professional, simply do not submit a consultation request.
11. Data Security
We use commercially reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized access, disclosure, alteration, and destruction. These include:
- Encryption of data in transit (TLS/SSL)
- Access controls limiting employee access to personal information
- Regular security reviews of our systems and vendors
- PCI-DSS compliance for payment processing through our third-party processors
However, no method of internet transmission or electronic storage is 100% secure. You acknowledge this inherent risk when using our Services.
12. Data Breach Notification
If we experience a data breach affecting your personal information that creates a real risk of significant harm, we will notify you and the appropriate regulatory authorities as required by applicable law (including the Office of the Privacy Commissioner of Canada under PIPEDA’s breach notification requirements).
13. International Data Transfers
Advisor Marketers operates in Canada and may transfer personal information to service providers located in the United States or other countries. When we transfer personal information across borders, we take steps to ensure it receives adequate protection through contractual safeguards and provider commitments. By using our Services, you consent to these transfers.
14. Children’s Privacy
Our Services are not intended for individuals under 18 years of age, and our Consumer Services specifically target users aged 55 and older. We do not knowingly collect personal information from children under 13 (the U.S. COPPA threshold) or from minors under 18 generally.
If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately and we will take steps to delete it.
15. Third-Party Websites and Services
Our Services may contain links to third-party websites or services not operated by us. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before providing them with information.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will:
- Update the “Effective Date” at the top of this Policy
- Post the revised Policy on this page
- Where required by law, notify you via email or a prominent notice on our Services
Your continued use of our Services after changes become effective constitutes acceptance of the revised Policy.
17. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact our Privacy Officer:
Privacy Officer Advisor Marketers Email: [email protected] General contact: [email protected]
Canadian residents who are not satisfied with our response have the right to contact the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca or the Office of the Information and Privacy Commissioner for British Columbia at https://www.oipc.bc.ca.
