PRIVACY POLICY

Our Commitment to You

Triumph Private Wealth LLC (“Triumph Private Wealth” “TPW” or the “Adviser”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”).

This Policy is addressed to any current clients and/or prospective clients of Triumph Private Wealth (“you” or “your”) whose public and non-public personal information TPW collects and controls to conduct its business, including on our website (“Site”).

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Triumph Private Wealth (also referred to as "we", "our" and "us") protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.

Triumph Private Wealth does not sell your personal information to anyone. Nor do we provide such information to others except for reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.

Why you need to know?

Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account(s). Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information through the sources identified below and on our Site. In particular, this Policy describes how we collect and use your personal information about you during and after your working relationship with us. In particular, this Privacy Policy describes the basis upon which and for what purposes we process your personal information, as well as your privacy rights under certain privacy laws including, where applicable, under US Privacy Laws, including the Gramm-Leach-Bliley Act - GLBA, and how we protect your personal information.

To affirm our continued commitment to the proper use of client information and protecting your privacy, we have set forth the following privacy policies.

Changes to Our Policy

We will provide our clients with this Privacy Policy when our relationship begins and an annual notice thereafter. You agree that delivery of these communications may be in electronic form. Changes may be posted to our website.

Periodically we may revise this Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.

What information do we collect from you?

When you establish a relationship with us, you are requested to furnish personal and financial information to assist in assessing your financial objectives and goals. The information you share with us is private and confidential, and we are committed to protecting your privacy. In addition to the information collected, during the course of our relationship we may also collect a variety of nonpublic and public personal information from other sources.

Social security or taxpayer identification number
Assets and liabilities
Name, address and phone number(s)
Income and expenses
E-mail address(es)
Investment activity
Account information (including other institutions)
Investment experience and goals

The specific types of personal information we collect and share depend on the service you have with us. In the preceding 12 months, we have collected the following categories of Personal Information:

personally identifying information such as name, telephone, address, date of birth, social security number, government identification, and marital status;
characteristics of protected classifications under California or federal law (e.g., gender, age);
digital footprint data such as e-mail, login information, and IP addresses;
biographical data such as age and gender;
employment data such as salary information, job position, and tax information;
financial Information such as bank information, salary information, credit card numbers, and pension.

How Your Personal Information is Collected from you:

The information that you voluntarily supply to us.
The information that you voluntarily supply to your registered investment adviser / financial professional.
The information that you supply to us voluntarily via the website, email, telephone, meetings, or mail.
Inferences drawn from any of the Personal Information identified (other than Sensitive Personal Information) above to create a profile about you reflecting your preferences, characteristics, and behavior.

What Information do we collect from other sources?

Custody, brokerage and advisory agreements
Account applications and forms
Other advisory agreements and legal documents
Investment questionnaires and suitability documents
Transactional information with us or others
Other information needed to service account[s]

How is your personal information used?

We will only use your personal information with the purpose to provide you with our investment services. In managing your investment for you, we will use your personal information to:

monitor, audit, evaluate and otherwise administer our services;
provide you with access to protected areas of our Site;
provide continuous service to you and to conduct business processing functions including by providing personal information to our related bodies corporate, contractors, service providers or other third parties;
assist with the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of TPW and its contractors and service providers;
communicate with you and respond to your inquiries;
conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms;
for other purposes required or authorized by law, including other purposes for which you have provided your consent;
protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities; and/or
perform data analyses (such as market and customer research).

In the event that we use personal information we collect for other purposes not identified above where direct client consent is required under applicable rules, laws and/or regulations we will provide specific notice at the time we collect such personal information.

How do we share your information?

An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information.

All financial companies need to share client’s personal information to run their everyday business. It is the policy of TPW to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide services in furtherance of the client's engagement of TPW.

In that regard, TPW may disclose the client’s information:

to individuals and/or entities not affiliated with TPW, including, but not limited to the client’s other professional advisors and/or certain service providers that may be recommended or engaged by TPW in furtherance of the client's engagement of TPW (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, proxy management service provider, etc.);
required to do so by judicial or regulatory process; or
otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.

Clients and/or prospective clients will be deemed to have automatically authorized Triumph Private Wealth to share any information contained in any document completed by a client and/or prospective client to TPW for the purpose of facilitating the business relationship with any corresponding nonaffiliated third-party service provider in connection to TPW providing such services (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.).

We limit access to nonpublic personal information to only those employees who have a business or professional reason for knowing it. Employees violating TPW’s Privacy Policy will be subject to TPW’s disciplinary process. TPW limits access to nonaffiliated third parties as permitted by law. Additionally, whenever TPW hires other third-party organizations to provide services to TPW’s clients, TPW will require them to sign confidentiality agreements and/or the Privacy Policy.

We do not provide your personal information to mailing list vendors or solicitors for any purpose.

Disclosure of any nonpublic personal information about our former clients is handled in the same manner as for our current clients.

In the section below pursuant to U.S. Federal Laws, we list the reasons financial companies can share their customers’ personal information; the reasons Triumph Private Wealth LLC chooses to share and whether you can limit this sharing.

Servicing our Clients

We may share non-public personal information with non- affiliated third parties (such as administrators, brokers, custodians, regulators, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations.

Do we share? Yes

Can you limit? No

Marketing Purposes

TPW does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where TPW or the Client has a formal agreement with the financial institution.

We will only share information for purposes of servicing your account(s), not for marketing purposes.

Do we share? No

Can you limit? Not Shared

Authorized Users

Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s).

Do we share? Yes

Can you limit? Not Shared

Information About Former Clients

TPW does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients.

Do we share? No

Can you limit? Not Shared

In the preceding 12 months, we have disclosed the following categories of your Personal Information for a business purpose:

Identifiers (e.g., a real name, postal address, email address, account name, other similar identifiers);
Personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual (e.g., employment, bank account number, financial information);
Characteristics of protected classifications under California or federal law (e.g., gender, age);
Commercial information (e.g., records of products or services purchased, obtained, or considered, or other purchasing histories);
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with our website);
Geolocation data (e.g., latitude or longitude);
Professional or employment-related information (e.g., securities licensing);
Inferences drawn from any of the information identified above (e.g., preferences, characteristics, or behavior); and
Sensitive personal information (e.g., tax identification number).

Can you limit our sharing?

To the extent U.S. Federal laws apply to your personal information, you have the right to limit only:

sharing for affiliates’ everyday business purposes;
affiliates from using your information to market to you; and
sharing for nonaffiliates to market to you.

U.S. state laws and individual companies may give you additional rights to limit sharing.

We do not solicit or wish to obtain the Personal Information of non-United States residents. By using our website or doing business with TPW, you represent that you are present and reside in the United States when you do so. Moreover, you agree that the law of the United States, and in particular, Orange County, Florida, shall apply to and govern your business with us.

What are your individual rights?

To the extent permitted by the applicable law of your jurisdiction, in relation to your personal information, you may request:

to have your personal information corrected, for example, if it is incomplete or incorrect;
to opt out of the sharing your Personal Information with third parties for their own marketing purposes;
the right to file a complaint with an applicable government regulator such as a Data Protection Authority.
the right to know the following with respect to Personal Information about you that we have processed within the past 12 months:

what specific information we have collected about you
what categories of Personal Information we have collected about you
the categories of the sources of Personal Information we have collected about you
the categories of Personal Information that we have shared with Third Parties for a business purpose about you and/or
the business or commercial purpose for collecting and sharing Personal Information

Right to be Forgotten or Deleted. You have the right to have your Personal Information that we collected from you deleted. Please note that your right to be forgotten/deleted is limited in some instances, including: (i) where we maintain applicable record-keeping rights, (ii) consistent with our regulatory/legal compliance requirements, (iii) if we need to keep your Personal Information to complete the transaction(s) for which it was collected, (iv) as reasonably necessary and proportionate to help ensure security and integrity, (v) to identify and repair errors; (vi) if another federal, state or other law preempts your right regarding deletion, (vii) if we have any right to retain the information by law or regulation that exists or later may be established over time. Please note that we will not usually be able to delete your information from back-up systems, but instead such information will be deleted or destroyed in accordance with routine back-up retention policies.
Likewise, we may continue to keep information that has been anonymized (i.e. your identifying information has been removed) or aggregated (your information has been added to a data pool but without your identifying information). We will not attempt to reidentify your deidentified Personal Information, except as provided by law.
Should you wish to correct errors or be forgotten/deleted, please contact us using the below-referenced phone number, email address or form. If you wish to opt out of our sharing of your Personal Information with Third Parties for their own marketing purposes, please follow the steps set out in this form.
You have the right to not be retaliated against by us because you exercised any of Your Rights under applicable privacy law. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

How do we protect your information?

To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. We will ensure that any technology vendors we may use to provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information.

We require third parties that assist in providing our services to you to protect the personal information they receive from us. We also contractually require any Third Parties that we may share your Personal Information with to comply with all privacy and security laws.

Internet Security Although we have made efforts to secure data that you submit to us on our Site, as our Site is linked to the internet which is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links to Third-Party Web Sites As a convenience to you, TPW may provide hyperlinks to web sites operated by third parties. When you select these hyperlinks, you will be leaving our Site.

TPW has no control over third party web sites, their content, or security. Accordingly, when you access these third-party web sites it is at your own risk. We encourage you to read the associated privacy policies by such third-party web sites to learn more about their data privacy management practices. TPW may, in its sole discretion, block links to our Site and Content without prior notice.

How do we keep your information accurate and up to date?

We will endeavor to ensure your personal information is kept accurate, complete, up to date and relevant. Please let us know if any of your details change. If you feel your personal information is not accurate, complete or up to date, please notify us and we will take reasonable steps to ensure it is corrected. You can contact us using the details listed below.

How long do we retain your information?

To the extent permitted by applicable law, we retain your personal information for the period necessary to serve the purposes for which we obtained it. We may also retain your personal information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest. The length of time we intend to retain your Personal Information is determined by the time period reasonably necessary for the disclosed purposes above; our routine back-up retention policies; any applicable legal, regulatory or other similar document retention requirements; and certain other legitimate purposes.

Does our Site collect information about children?

Our Site is not directed to children under the age of 18 years. By using our Site, you represent and warrant that you are at least 18 years old. We do not knowingly solicit or collect personal information on our Site from children under the age of 18 without prior verifiable parental consent.

Who is the data controller?

As identified under applicable law, the data controller for this policy is TPW, located at the address below.

Any Questions?

If you have any questions regarding this privacy policy or would like to exercise your rights, you may contact our Chief Compliance Officer using the information below:

Attention: Jonathan Kreidt Triumph Private Wealth LLC, 2754 N Rio Grande Avenue, Orlando, FL 32804 E-mail: jonathan@triumphpw.com Web: www.triumphpw.com

Definitions

Affiliates: Companies which control, or are under common ownership or control with, Triumph Private Wealth LLC.

“Third Party” or “Third Parties” parties that do not control, or are not under common ownership or control with, Triumph Private Wealth LLC.

“Personal Information” about you, for purposes of this policy, is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

“Sensitive Personal Information” about you, for purposes of this policy, is as defined in applicable privacy law and includes, without limitation, non-public Personal Information that reveals your social security, driver’s license, state identification card, or passport number.