Privacy Policy (FINRA / Regulation S-P Compliant Notice)
At Meristem Private Wealth, protecting your privacy and safeguarding your nonpublic personal information (“NPI”) is a top priority. This Privacy Policy explains how we collect, use, disclose, and protect your information in compliance with the Gramm-Leach-Bliley Act (GLBA), SEC Regulation S-P, FINRA rules, and other applicable laws.
This policy applies to the Site and our client relationships. It supplements LPL Financial’s privacy notices (as our broker-dealer and advisor affiliate).
Information We Collect
We may collect NPI from you directly (e.g., via forms, applications, or communications), from your transactions, and from other sources. Categories include:
- Contact and Identifying Information: Name, address, email, phone number, Social Security number, date of birth.
- Financial Information: Income, assets, account balances, investment objectives, transaction history, and tax-related data.
- Other: Employment history, risk tolerance, and information needed to provide services.
We also collect non-personal data such as website usage (cookies, IP address, browser type) for analytics and to improve the Site.
How We Use Your Information
We use your information to:
- Provide and administer financial planning, investment advisory, and related services.
- Process transactions and maintain your accounts.
- Comply with legal, regulatory, and tax requirements (including FINRA and SEC obligations).
- Communicate with you about services, updates, and important notices.
- Detect and prevent fraud, and enhance security.
How We Share Your Information
We do not sell your NPI. We may share it as follows:
- With Affiliates and Service Providers: With LPL Financial and trusted third parties (e.g., custodians, accountants, attorneys) who help deliver services. These parties are contractually obligated to maintain confidentiality.
- For Legal and Regulatory Reasons: As required by law, court order, or to protect our rights (e.g., to regulators like FINRA or the SEC).
- With Your Consent: In other cases, only with your permission.
We do not share NPI with nonaffiliated third parties for their marketing purposes.
California Residents: Additional rights may apply under the California Consumer Privacy Act (CCPA). See LPL’s notices for more.
Security of Your Information
We maintain physical, electronic, and procedural safeguards to protect your NPI against unauthorized access, use, or disclosure. This includes encryption, access controls, and employee training. No security system is infallible, but we take reasonable steps consistent with industry standards.
In the event of a breach affecting your NPI, we will notify you as required by law.
Retention
We retain your information as long as necessary to provide services, comply with legal obligations (e.g., SEC/FINRA recordkeeping), and resolve disputes.
Your Rights and Choices
- Access and Correction: You may request access to or correction of your information.
- Opt-Out: Limit certain sharing by contacting us.
- Annual Privacy Notice: We provide this notice annually (or as required); an exception may apply if policies have not changed and sharing is limited to permitted exceptions.
To exercise rights or for questions, contact us at the details above or via LPL’s Privacy Office.
Children’s Privacy
The Site is not directed to children under 13. We do not knowingly collect information from children.
Changes to This Policy
We may update this Privacy Policy. Changes will be posted here with an updated effective date. Continued use constitutes acceptance.
This document is for informational purposes and does not replace your client agreements or LPL Financial’s full privacy notices. For the most current LPL notices, visit their site.
Important Disclosures: Securities and advisory services offered through LPL Financial. Member FINRA/SIPC. Meristem Private Wealth is not an affiliate of LPL Financial. Check BrokerCheck at brokercheck.finra.org for more information.