Privacy Policy

Purpose1st, LLC (doing business as "Purpose1st Financial," "we," "our," or "us") is a registered investment advisor providing wealth management and financial planning services to clients throughout the United States. Our primary state of registration is Ohio, regulated by the Ohio Division of Securities. We may also operate in other states in accordance with applicable notice-filing or exemption requirements.

This Privacy Policy applies to all personal information we collect in connection with our advisory services, our website at purpose1st.co, and any electronic, telephone, or written communications between you and our firm. It covers:

• Current and former clients and their authorized representatives
• Prospective clients who submit inquiries or consultation requests
• Visitors to our website at purpose1st.co

By using our services or website, you acknowledge the practices described in this policy.

We collect personal information necessary to provide financial advisory services and to comply with applicable law. The categories of information we collect include:

IDENTIFYING INFORMATION

• Full legal name, date of birth, Social Security number or Tax Identification Number
• Government-issued identification (driver's license, passport)
• Spouse, partner, or family member information relevant to joint planning

CONTACT INFORMATION

• Mailing address, email address, telephone number
• Preferred method and frequency of communication

FINANCIAL INFORMATION

• Income, net worth, assets, liabilities, and account balances
• Brokerage and custodial account numbers and holdings
• Tax returns, financial statements, and estate planning documents
• Insurance policies, retirement plan information, and employee benefits
• Investment objectives, risk tolerance, and time horizon

TRANSACTION AND ACCOUNT DATA

• Records of securities transactions, advisory fee payments, and account activity
• Trade confirmations and account statements

PROFESSIONAL AND BACKGROUND INFORMATION

• Employment status, occupation, and employer information
• Business ownership and interests
• Prior investment history and experience

WEBSITE AND TECHNICAL INFORMATION

• IP address, browser type, operating system, and device identifiers
• Pages visited, time spent, and referral URLs
• Information submitted through web forms, including consultation requests

We collect this information directly from you, from your authorized representatives, from your custodian or financial institutions (with your authorization), and in limited cases from publicly available sources.

We use your personal information strictly for legitimate business and legal purposes, including:

• Providing, administering, and improving our financial advisory and planning services
• Opening, maintaining, and reviewing client accounts and investment portfolios
• Communicating with you regarding account activity, market conditions, and firm updates
• Responding to consultation requests and other inquiries
• Fulfilling legal, regulatory, and compliance obligations as a registered investment advisor
• Detecting and preventing fraud, unauthorized access, and other illegal activity
• Maintaining accurate books and records as required by federal and state law
• Improving the functionality and content of our website

We do not sell, rent, lease, or otherwise trade your personal information to third parties for their marketing purposes. We do not use your information for automated decision-making or profiling in ways that produce legal or significant effects without human review.

We treat all client information as strictly confidential. We do not share your personal information with unaffiliated third parties except in the following limited circumstances:

SERVICE PROVIDERS

We engage third-party custodians (such as Charles Schwab and Co., Inc.), technology platforms, compliance vendors, accountants, and professional service firms to support our operations. Each is subject to confidentiality obligations and is permitted to use your information only to perform services on our behalf.

LEGAL AND REGULATORY REQUIREMENTS

We may disclose your information as required by law, court order, subpoena, or regulatory authority, including the SEC, FINRA, the Ohio Division of Securities, the IRS, and other applicable federal and state agencies.

WITH YOUR CONSENT

We share information with third parties you have designated, such as your attorney, accountant, co-trustee, or other financial professionals, when you have provided written or verbal authorization.

BUSINESS TRANSFERS

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of our assets, your information may be transferred to a successor entity. We will provide notice of such a transfer and ensure that the successor is bound by appropriate privacy protections.

PROTECTION OF RIGHTS

We may disclose information when we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Purpose1st Financial, our clients, or others.

We collect nonpublic personal information ("NPI") about you from information you provide on forms and applications, information about your transactions with us or with others, and information we receive from third parties you authorize. We do not disclose any NPI about our clients or former clients to any nonaffiliated third party except as permitted by law.

We restrict access to NPI to those employees, contractors, and service providers who have a legitimate need to know that information in order to provide services to you. We maintain physical, electronic, and procedural safeguards designed to comply with federal standards for the protection of NPI.

Regulation S-P requires that we deliver this privacy notice to you at the time you become a client and annually thereafter for as long as you remain a client. If there are changes to our information-sharing practices that would require you to receive a revised notice and the opportunity to opt out, we will notify you in advance.

Under the GLBA and Regulation S-P, you have the right to opt out of certain information sharing with nonaffiliated third parties. However, because Purpose1st Financial does not share your NPI with nonaffiliated third parties for purposes beyond those listed in this policy (and does not sell or market your information), there is currently no opt-out available that would further limit our use of your information.

We will notify you promptly if our sharing practices change in a way that gives rise to an opt-out right. To exercise any available opt-out rights, contact us using the information in Section 16.

Certain state laws may provide additional opt-out rights. Please see Section 12 for state-specific information.

When you submit a consultation request or other inquiry through our website, we collect the information you provide (name, email address, and message content) for the purpose of responding to your inquiry. This information is transmitted to our team and may be used to initiate an advisory relationship.

If you become a client, we may communicate with you by email, secure client portal, telephone, or postal mail. You may indicate your preferred communication method and you may instruct us to limit or restrict certain forms of electronic communication at any time.

Please be aware that email communications are not fully secure. We recommend that sensitive financial information be shared through our secure client portal or encrypted channels. We are not responsible for the security of email communications transmitted over public or unsecured networks.

Our website at purpose1st.co may collect technical information automatically when you visit, including your IP address, browser type, operating system, referring URLs, and pages visited. This information helps us understand how visitors use our site and improve its content and functionality.

COOKIES AND SIMILAR TECHNOLOGIES

We may use cookies, web beacons, and similar technologies to enhance your experience on our site. Cookies are small text files stored on your device that help us recognize return visitors and understand usage patterns. We do not use cookies to build advertising profiles or to sell your data.

You may configure your browser to refuse cookies or to alert you when cookies are being sent. Please note that some portions of our website may not function properly if cookies are disabled.

ANALYTICS

We may use third-party analytics tools to understand site traffic and user behavior in aggregate. These tools may collect information about your visit in anonymized or aggregated form. We do not combine this information with personally identifiable information without your consent.

DO NOT TRACK

Our website does not currently respond to "Do Not Track" signals sent by browsers. We will update this policy if our practices change.

Our website may contain links to third-party websites, including financial regulators (such as the SEC and FINRA), custodians, and other resources. These websites are governed by their own privacy policies, which may differ substantially from ours. We are not responsible for the privacy practices, content, or security of any third-party website.

We encourage you to review the privacy policies of any third-party sites you visit. The inclusion of a link on our website does not constitute an endorsement of the linked site or its content.

We implement a layered approach to protecting your personal information, including:

• Encryption of sensitive data in transit using industry-standard TLS protocols
• Restricted employee access to personal information on a strict need-to-know basis
• Multi-factor authentication for systems containing client data
• Secure storage and disposal of physical documents containing sensitive information
• Regular review and updating of our security policies and procedures
• Vendor due diligence to ensure third-party service providers maintain appropriate safeguards

In the event of a data breach that involves your personal information, we will notify you as required by applicable federal and state law, including the laws of your state of residence.

No method of electronic transmission or storage is completely secure. While we apply commercially reasonable measures, we cannot guarantee absolute security against all possible threats.

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to maintain our advisory relationship with you, and to comply with applicable legal and regulatory requirements.

Specifically:

• Client account records and advisory files are retained for a minimum of five (5) years following the termination of the advisory relationship, consistent with SEC and state securities law requirements
• Financial planning documents are retained for a period appropriate to the nature of the plan and applicable law
• Website inquiry and consultation request data is retained until the inquiry is resolved and for a reasonable period thereafter
• Records required by the IRS, FINRA, or other regulatory bodies are retained for the periods those regulations specify

When information is no longer needed and no longer required to be retained, we securely destroy or anonymize it.

Depending on your state of residence, you may have additional rights regarding your personal information. We honor these rights for all clients and prospective clients, regardless of state, to the extent practicable.

CALIFORNIA (CCPA / CPRA)

California residents have the right to: (i) know what personal information we collect and how it is used and disclosed; (ii) request deletion of personal information, subject to certain exceptions; (iii) opt out of the "sale" or "sharing" of personal information (we do not sell or share your personal information for cross-context behavioral advertising); (iv) correct inaccurate personal information; (v) limit the use of sensitive personal information; and (vi) not be discriminated against for exercising these rights.

To submit a verifiable consumer request, please contact us using the information in Section 16. We will respond within 45 days.

COLORADO, CONNECTICUT, TEXAS, VIRGINIA, AND OTHER STATE PRIVACY LAWS

Residents of states that have enacted comprehensive consumer privacy laws may have rights similar to those listed above, including rights to access, correct, delete, and port personal data, as well as to opt out of certain data processing. We will honor applicable rights upon receipt of a verified request.

ALL STATES

Regardless of your state of residence, you may contact us at any time to request access to, correction of, or deletion of personal information we hold about you, subject to applicable legal and regulatory record-retention requirements. See Section 14 for details on how to make such a request.

Our services and website are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a person under 18, we will take prompt steps to delete that information.

If you believe we have collected information from a minor, please contact us immediately using the information in Section 16.

You have the right to access, review, and request corrections to the personal information we maintain about you. To exercise these rights:

• Submit a written request to contact@purpose1st.co with the subject line "Privacy Request"
• Include your full name, mailing address, and a description of the information you wish to access or correct
• We will verify your identity before fulfilling any request
• We will respond within 30 days of receiving a verified request, or within the timeframe required by applicable law if shorter

Please note that certain information may be subject to legal hold or regulatory record-retention requirements that limit our ability to delete or alter it.

We may update this Privacy Policy from time to time to reflect changes in our information practices, applicable law, or the services we provide. Material changes will be communicated to active clients in writing (by email or postal mail) at least 30 days before they take effect.

The "Last Updated" date at the top of this policy reflects the most recent revision. We encourage you to review this policy periodically. Continued use of our services after the effective date of a revised policy constitutes acceptance of the updated terms.

If we make changes that require your opt-out right under applicable law, we will provide a new notice and opt-out opportunity before implementing those changes.

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or wish to raise a concern about how your information has been handled, please contact us:

For California residents wishing to submit a CCPA request, please use the email above with the subject line "CCPA Request."