Advisor360°, LLC privacy notice

Effective Date/Last Updated: October 2026

 

Introduction

Advisor360°, LLC, along with our service providers and other third parties acting on our behalf, (together “Advisor360°,” “we,” “our,” or “us”) respects the privacy of your information. This Portal Privacy Policy is designed to assist you in understanding how we collect, use, disclose, and safeguard your information. 

This Portal Privacy Policy applies to individuals who access our online portal (the “Portal”) and any related online services that we make available through the Portal (collectively, “Services”). This Portal Privacy Policy is distinct from our public general privacy policy and describes how we process personal data in connection with the Portal, including account credentials and Portal usage information for which we act as a data controller. You are consenting to our use of your personal data in accordance with this Portal Privacy Policy by using the Portal or Services.

Please note that much of the investment and account information you see in the Portal is provided and controlled by your financial institution, broker‑dealer, registered investment adviser, or other firm (your “Firm”). Your Firm’s own privacy notice explains how your Firm uses and shares that information.

From time to time, we may update this Portal Privacy Policy. If we do, we will post the updated version on this Portal with a new “last updated” date. Any changes will go into effect as soon as they are posted to the Portal unless stated otherwise. Please review this Portal Privacy Policy periodically as your continued use of the Portal or Services will constitute your consent to any such updates.

Personal Data We Collect 

We collect personal data from you through your use of this Portal and Services as well as from other third parties during the course of our relationship with you. Personal data is information that is linked or reasonably linkable to an identified or identifiable individual. 


We collect information about users of our Portal from the following sources:

As a service provider to our customers, we collect information about our investment professional clients and their clients that use our Portal. The information we collect depends on the products or Services used, and may include information our customers enter into the Portal directly, as well as information that our customers' end clients provide to our investment professional clients, such as:

  • Information that you provide directly to us, including information you enter into or otherwise provide to our Portal
  • If you are a client of one of our investment professional clients, we receive information about you from your investment professional
  • Information from third-party data services or feeds from other financial institutions regarding your transaction history
  • Other sources with your consent, or if you are a client of one of our investment professional clients, with the consent of your investment professional

Portal Users 

As a service provider to our customers, we collect information about our investment professional clients and their clients that use our Portal. The information we collect depends on the products or Services used, and may include information our customers enter into the Portal directly, as well as information that our customers' end clients provide to our investment professional clients, such as:

  • Identifiers, which may include name, address, email address, telephone number, Social Security number, signature, driver’s license or state identification card number, professional or employment-related information and history, passport number, or other similar identifiers, and other financial information
  • Protected classification information, which may include age, sex, gender, national origin, citizenship, race, ethnicity, marital status, disability status
  • Financial information, which may include net worth, assets, income, investment experience
  • Commercial information, which may include account balances, trading history, payment history, transactions or credit relationships with non-affiliated third parties
  • Internet or other electronic network activity information, which may include, but is not limited to, internet protocol address, browsing history, search history, and information regarding your interaction with our website, Portal, or advertisement
  • Geolocation data
  • Sensory data, which may include audio and video recordings
  • Biometric information, which may include fingerprints
  • Professional or employment related information, which may include employer name, status, and history
  • Education information, which may include grades, transcripts, training, and certifications
  • Inferences, which may include profiles, preferences, characteristics, and behaviors

In addition, we collect the following types of personal data:

 
Personal Data You Provide 

Depending on how you interact with our Portal and Services, we will collect the following personal data that you voluntarily provide to us for the following purposes:

  • Create and manage a Portal account. If you register for or are provisioned with access to the Portal, we may request or receive your name, email address, Firm affiliation, and other information needed to create, manage, and secure your account.

  • Use the Services. When you use the Portal and Services, we may collect information you submit or generate, such as preferences, settings, documents you upload, and information needed to generate views and reports made available through the Portal on behalf of your Firm.

  • Contact Us/Support Requests. If you contact us (or your Firm contacts us on your behalf) about the Portal, we may receive your name, contact information, and any other information you choose to include in your communications with us, such as details about a technical issue or support request. 

We may collect other personal data for our legitimate business purposes and as otherwise appropriate during the course of our relationship with you.

Personal Data Collected by the Portal

We automatically collect certain personal data through your use of our Portal through cookies and other tracking technologies, such as the following: 

  • Usage Information. For example, the pages and URLs you visit or features you use on the Portal and how you navigate through the Portal.

  • Technical and Log Information. For example, TCP/IP addresses and other technical information about you or your devices that are generated when you access or use the Portal, such as device type, browser type, access dates and times, and system activity.

  • Referring Information. For example, referring websites, applications, and other origination points that lead you to our Portal.

 
Personal Data We Collect About You from Other Sources 

In some cases, we may receive personal data about you from other sources, such as your Firm, custodians, and other service providers and integration partners that support the Portal. 

  • Your Firm and integration partners. We may receive personal data about you from your Firm and from third parties that provide services to your Firm (such as custodians, account aggregation providers, or planning tools) so that this information can be displayed or used within the Portal and Services.

  • Other third parties. We may receive personal data about you from other third parties, which may include advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, data brokers, and any other third parties that we deem appropriate to further our legitimate business purposes or with your consent.

How We Use Your Personal Data

In addition to the purposes stated above, we may use any or all of the personal data we collect as follows in accordance with applicable law such as to: 

  • Manage, maintain, and provide our Portal and Services;

  • Provide services made available through the Portal, including displaying investment and account data and generating reports on behalf of your Firm;

  • Communicate with you about our Portal or Services, including providing you with Portal-related content or other information that may be of interest to you;

  • Troubleshoot and diagnose technical issues;

  • Detect, monitor, and mitigate privacy, security, and other operational risks;

  • Optimize navigation, content, and other features of the Portal or Services;

  • Support technical and product-development efforts to improve the user experience on the Portal or through the Services; and

  • Comply with applicable laws and regulations or respond to law enforcement or legal processes.

We may also use personal data for our legitimate business purposes and as otherwise appropriate during the course of our relationship with you.

We may deidentify your information to make it anonymized. We publicly commit to maintain and use the information in deidentified form and not to attempt to reidentify the information.

 

How We Disclose Your Personal Data

We may disclose the personal data that we collect about you in the following ways:

  • With service providers who assist us in operating our organization, Portal, or Services, including data analytics providers (if implemented), hosting providers, and other technology vendors;

  • With your Firm (such as your financial institution, broker‑dealer, or registered investment adviser) and its authorized users, as necessary to operate the Portal and related Services and to support your Firm’s supervisory, compliance, and support functions;

  • With third parties as required by law or legal process;

  • To protect our rights, privacy, safety, or property, or that of others; or

  • With your consent or at your direction.

We may also disclose personal data for our legitimate business purposes and as otherwise appropriate during the course of our relationship with you.

Except as may be required by law or as described in this Portal Privacy Policy, we do not sell, rent, or otherwise disclose the personal data we collect. We may disclose personal data to third-party service providers for limited business purposes, as described above.

 

Cookies and Other Tracking Technologies

Like many other companies, we use cookies and other tracking technologies (collectively, “Cookies”) on our Portal. We may use Cookies to:

  • Help secure your account, facilitate authentication, and enable you to remain logged in while you use the Portal;

  • Compile aggregate statistics about Portal usage to help us maintain, monitor, and improve the Portal and Services; or

  • Recognize when you return to the Portal. 

We set some Cookies ourselves, while third parties may also deploy Cookies when you use our Portal. These third parties provide us insight to help us improve our Portal and Services and to analyze performance and usage. These third parties may collect personal data about your online activities over time and across different websites or applications when you use the Portal, depending on how their services are configured. You may be able to opt out of Cookies that are set by these third parties by opting out of each individually.

Your Internet browser settings may also allow you to control the placement of some Cookies. If you choose to block Cookies (including essential Cookies) you may not be able to access all or parts of the Portal.

Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you may need to opt out on every browser and device that you use.

Our Portal does not currently respond to “Do Not Track” signals or similar mechanisms sent by web browsers. However, you may use the other tools, such as opt-out preference signals, or as otherwise described in this Portal Privacy Policy (such as browser settings and third-party opt-out links) to manage your cookie preferences and other tracking technologies.

 

AI-Enabled Features

If your Firm has enabled AI-enabled features through the Portal, such as a virtual assistant or meeting transcription and summarization tools, we collect and use your inputs, recordings, transcripts, and summaries to operate and provide those features. We do not use your or your Firm's data, including client data, to train or fine-tune the underlying artificial intelligence models.

 

Advisor360° Outlook

If you install the Advisor360° Outlook add-in, we access information in your Outlook mailbox, including the subject, body, sender and recipient information, and attachments of your email, in order to sync your email activity with the Advisor360° Customer Relationship Management (CRM) software. If your organization uses shared or delegated mailboxes, this access may extend to those mailboxes as well, and requires your organization's administrator to consent. The add-in uses Microsoft's own sign-in process, so we never see or store your Microsoft password. Each customer organization's data is isolated from every other customer's. We retain mailbox content synced to the CRM for at least seven (7) years, consistent with our retention of other CRM correspondence. To uninstall the add-in or request deletion of previously-synced data, contact us as described in the "How to Contact Us" section below.

 

Security

We maintain reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or data transmission over the Internet is 100% secure, so we cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your Portal credentials and for restricting access to your devices. Please notify your Firm or us promptly if you believe your Portal account or credentials have been compromised.

 

Third-Party Links

The Portal may contain links that will let you leave the Portal and access another website. Linked websites are not under our control, and we are not responsible for and do not endorse the privacy practices, security measures, content, views, or accuracy of information on any third-party websites. Your use of such linked websites is subject to the terms and privacy policies of those third parties.

 

Children’s Information

The Portal is not intended for use by children under the age of 13, and we do not knowingly collect personal data from children under 13 through the Portal. If we become aware that a child under 13 has provided us with personal data through the Portal in violation of applicable law, we will delete any such personal data we have collected, unless we have a legal obligation to keep it. If you believe that a child under 13 has provided personal data to us through the Portal, you may contact us as described in the “How to Contact Us” section below.

 

How to Contact Us

If you have any questions about this Portal Privacy Policy or our privacy practices, please contact us through our webform by clicking on this link.