Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this policy carefully to understand what we do with the personal information collected. Pure Financial Advisors, LLC (“PURE”) takes your privacy very seriously. We are committed to protecting your privacy and the confidentiality of your personal and financial information. If you have any questions or concerns about this privacy policy, or our practices with regards to your personal information, please contact us immediately.

As agents of products and services that involve compiling personal and sometimes sensitive information, protecting the confidentiality of that information is a top priority for PURE and its employees. Whether you are a current, former, or potential client, we believe that you should know about the information we collect, our efforts to safeguard it, and situations in which we may share information with select business partners. Our website privacy statement is also available at www.purefinancial.com.

The information we collect and the extent to which we use it will vary depending on the product or service involved. Our intention is to only share information to the extent that is required or in our opinion necessary to achieve the maximum benefits from our products and services for our clients. Our privacy policy derives from basic principle of trust, ethics, and integrity.

What?

We collect only the information necessary to identify needs and appropriate solutions and services for our clients.

PURE may collect personal information and sensitive personal information that helps us serve your financial needs, provide high standards of service, develop, and offer new services, products, and strategies for our clients and to fulfill our legal and regulatory requirements.

“Personal information” is information that identifies, relates to, or could reasonably be linked with you or your household. For example, it could include your name, social security number, email address, records of products purchased, internet browsing history, geolocation data, and inferences from other personal information that could create a profile about your preferences and characteristics.

Personal information does not include publicly available information that is from federal, state, or local government records, such as professional licenses and public real estate/property records. The definition of publicly available information also includes information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media, or certain information disclosed by a consumer and made available if the consumer has not restricted the information to a specific audience.

“Sensitive Personal information (SPI)” pertains to any private information that divulges any of the following: (a) Personal identification numbers, including social security, driver’s license, passport, or state ID card numbers; (b) Account or debit or credit card numbers combined with passwords or codes that would enable access to the accounts; (c) a consumer’s exact geolocation; (d) consumer’s racial origin, religious beliefs, or union membership; (e.g.) a consumer’s mail, email, or text message content unless the information was intentionally sent to the business.

The information collected varies depending on the products and services you request and may include the following:

  1. Information provided in personal meetings, telephone interviews, applications, and related forms such as name, social security number, annual income, or other personal and financial information helpful to determine an appropriate product or service.
  2. Responses from your employer, benefit plan sponsor, or association regarding any group products we may provide, for example name, age, address, and social security
  3. Information about your relationship with us, such as products or services purchased, and account balances (if applicable), which we may obtain in writing, during telephone or internet transactions or from data gathering software used when you access our web

We maintain safeguards to ensure information security.

We have implemented security standards and processes, including physical, electronic, and procedural safeguards to ensure that access to client information is limited to employees or client authorized professional service providers, who may need access to do their jobs. All persons with access are required to respect the confidentiality of all client information.

How?

We limit how, and with whom we share information.

All financial companies need to share clients’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their clients’ personal information; the reasons PURE chooses to share; and whether you can limit this sharing .

We do not sell lists of our clients or client information. We do not disclose client information, with the exception of companies or individuals we hire to provide specific services for us and our clients, as described below.

We share client information for the following reasons:

To be more specific, there are various circumstances where we may need to process your data or disclose your personal information as follows:

  • Business Transfers: Your information may be shared or transferred during negotiations of any merger, financing, sale of company assets, or acquisition of all or part of our business to another company.
  • Vendors, Consultants, and Other Third-Party Service Providers: We may share your data with third-party vendors, service providers, contractors, or agents who perform services on our behalf and require access to your information to do so. Examples include payment processing, email delivery, data analysis, hosting services, customer service, and marketing efforts, as well as compliance with legal or regulatory requirements, and endorsement to financial institutions. We may also allow selected third parties to use tracking technology on our website to collect data about how you interact with our website over time, which may be used to analyze and track data and better understand online activity. We do not share, sell, rent, or trade your information with third parties for their promotional purposes, except as described in this policy. All contracts or agreements with these third parties will contain provisions requiring them to protect consumer data privacy rights and comply with applicable federal data privacy laws.
  • Affiliates: We may share your information with our affiliates, which include subsidiaries, joint venture partners, investors, or other companies that we control or are under common control with us, including our employees and advisors. In such cases, we require our affiliates to comply with this privacy policy and protect consumer data privacy rights in accordance with applicable federal data privacy laws.
  • Business Partners and Non-Affiliates: We may share your information with our business partners and non-affiliates to provide you with better services or promotions. In such cases, we require our business partners and non-affiliates to protect consumer data privacy rights in accordance with applicable federal data privacy laws.

Specific Privacy Rights for California Residents

California residents are granted specific rights regarding access to personal information.

Who qualified as a California resident?

The California Code of Regulations defines a “resident” as:

  • every individual who is in the State of California for other than a temporary or transitory purpose and,
  • every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose All other individuals are defined as “non-residents.”

Categories of Information Shared in the Last Twelve (12) Months

We have collected the following categories of personal information in the last twelve (12) months. The categories of information are based on the non-exclusive categories under the CCPA and CPRA.

In summary, California residents have the following privacy rights:

  • Right to Access – If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.
  • Right to Correct and Delete Inaccurate Personal Information – If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
  • Right to Opt Out of Sale of Personal Information – If you are a California resident, you have the right to “opt out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA).
  • Right to Delete. – If you are a California resident, you have a right to request the deletion of their personal information held by businesses and requires those businesses to comply with such requests, subject to certain exceptions.
  • Right Against Discrimination – against Californians who exercise their privacy right under the law.
  • Process to Make a CCPA Request – Making Access and Deletion Requests: To make an access or deletion request, please use the contact information provided below Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
  • Instructions for Authorized Agents Making Access and Deletion Requests – You may also use an authorized agent to submit an access or deletion request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with California probate law. Authorized agents that are business entities must be registered with the California Secretary of State to conduct business in California. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity.
  • Shine the Light Act – If you are a California resident, California Civil Code Section 1798.83 permits you to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

Making Requests to “Opt Out” of the “sale” of “Personal Information”

Please note that PURE DOES NOT sell personal information and notice will be given if there is a change in this policy.

If there is such a change a policy wherein, we sell personal information, you may submit a request to opt out of the sale of your personal information, you may visit our “Do Not Sell My Personal Information” page which will automatically be added in our official website if there is a change in policy. You may also send an email to the contact information provided below to request the same.

You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so.  Authorized agents may submit requests to opt out by email.

Information from Minors

We do not knowingly collect data from or market to children under 18 years of age. Clients, when providing their personal information, are asked to confirm that they are 18 years or older.

To Limit Our Sharing

In accordance with applicable state laws, you have the right to limit our sharing of your personal information.  You may submit a request to exercise your data privacy rights as described in this privacy policy using the information below.

Call us at 1 (877) 222-6044

By email: compliance@purefinancial.com

By mail at 3131 Camino Del Rio North, Suite 1550 San Diego, CA 92108

We verify who you are before giving you access to your data or making any changes to it by asking for certain information or documents to prove your identity.

We will respond to your request within 45 days of verifying your identity. If we require more time to respond, we will notify you of the reason and extension period in writing. We may require you to provide additional information to verify your identity and the authenticity of the request. We will not discriminate against you for exercising your consumer rights.

Please note:

If you are a new client, we can begin sharing required information immediately upon the start of our relationship. When you are no longer our client; we may be required to continue to share your information as described in this policy. However, we are limited to sharing only the information required by law or regulation, such as in response to a subpoena or to comply with industry regulators.

Companies with which we share client information are required to maintain the confidentiality of that information. In those states where privacy or consumer information laws are more restrictive than our privacy policy, we will restrict our sharing of your information to comply with state law.

We will affirm this policy annually in writing, as long as you maintain an ongoing relationship with PURE While this policy may change from time to time, you can request a copy of the current policy by emailing compliance@purefinancial.com . In this notice of our privacy policy, the words “you” and “client” are used to mean any individual who obtains or has obtained a financial product or service through a PURE representative.

Last updated: April 2023.

Cookies Policy

This cookies policy explains how Pure Financial Advisors, LLC (“PURE”, “we”, “us”, or “our”) uses cookies and other similar technologies on our website www.purefinancial.com (the “Site”).

What are cookies?

Cookies are small text files that are placed on your device when you visit a website. Cookies are used to remember your preferences, analyze how you use the Site, and personalize your online experience.

What cookies do we use?

We use the following categories of cookies on our Site:

  1. Strictly Necessary Cookies: These cookies are essential for the operation of the Site and cannot be disabled in our systems. They are usually set in response to actions you take on the Site, such as filling out forms or setting preferences.
  2. Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Site. They help us understand which pages are popular and how visitors move around the Site.
  3. Functional Cookies: These cookies enable the Site to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our Site.
  4. Targeting Cookies: These cookies may be set through our Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites.

Do we use third-party cookies?

Yes, we use cookies from third-party providers, such as Google Analytics, to help us analyze how visitors use the Site. These third-party providers may also use cookies to serve ads based on your past visits to the Site and other websites.

Do we honor “Do Not Track” signals?

We do not currently honor “Do Not Track” signals. However, you can opt-out of certain cookies by following the instructions in the “How can you control cookies?” section below.

How can you control cookies?

You can control cookies by adjusting your browser settings. Most browsers allow you to block cookies or to delete cookies already stored on your device. However, if you block or delete cookies, some features of the Site may not work properly.

In addition, you can opt-out of certain cookies by using the following links:

Google Analytics: https://tools.google.com/dlpage/gaoptout

Changes to this Cookies Policy

We may update this cookies policy from time to time. Any changes we make will be effective immediately upon posting to the Site.

Contact Us

If you have any questions or concerns about our use of cookies, please contact us at compliance@purefinancial.com .